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Agenda Document Pack - Audit Committee - 23/02/2026

Midlothian Council · 23 February 2026
Back to Audit Committee — 23 February 2026 and its agenda

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Notice of Meeting and Agenda 
Audit Committee 
Venue:  Normandy Court/ Hybrid, 
Normandy Court, 20 Normandy Dr, Dalkeith, EH22 1JG 
Date:  Monday, 23 February 2026 
Time:  11:00 
Executive Director : Place 
Contact:
Clerk Name: Democratic Services
Clerk Telephone: 
Clerk Email: democratic.services@midlothian.gov.uk 
Further Information: 
This is a meeting which is open to members of the public.  
Privacy notice: Please note that this meeting may be recorded. The
recording may be publicly available following the meeting. If you would
like to know how Midlothian Council collects, uses and shares your
personal information, please visit our website: www.midlothian.gov.uk 
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1          Welcome, Introductions and Apologies   
2          Order of Business 
Including notice of new business submitted as urgent for consideration at the
end of the meeting. 
3          Declaration of Interest 
Members should declare any financial and non-financial interests they have in
the items of business for consideration, identifying the relevant agenda item
and the nature of their interest. 
4          Minute of Previous Meeting
4.1 Minute of the Audit Committee meeting of 2 December 2025
submitted for approval
5 - 16
4.2 Action Log 17 - 20 
5          Public Reports
5.1 Midlothian Council Annual Audit Plan 2025/26, report by Audit
Director, Audit Scotland
21 - 42
5.2 Local Government in Scotland: Financial Bulletin 2024/25, report
by Chief Finance Officer and Section 95 Officer
43 - 88
5.3 Treasury Management and Investment Strategy 2026/27 &
Prudential Indicators, report by Chief Finance Officer and Section
95 Officer
89 - 166
5.4 Internal Audit Work to January 2026, report by Chief Internal
Auditor
167 - 178
5.5 Internal Audit Strategy and Annual Plan 2026/27, report by Chief
Internal Auditor
179 - 196
5.6 Counter Fraud Annual Plan 2026/27, report by Chief Internal
Auditor
197 - 202
5.7 Strategic Risk Management – Strategic Risk Profile Quarter 3,
2025-26, report by Chief Officer Place
203 - 246 
6          Private Reports 
No items for discussion 
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7          Date of Next Meeting 
The next meeting will be held on Monday 15 June 2026 at 11am. 
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Audit Committee        
Monday 23 February 2026
Item No 4.1 
Audit Committee 
Date Time Venue
Tuesday 2 December 2025 11:00am MS Teams 
Present:
Councillor McEwan (Chair)  Councillor Bowen 
Councillor McCall Councillor Milligan
Councillor Smaill 
In Attendance:
Councillor Alexander Councillor McKenzie
Councillor Parry Councillor Pottinger
Councillor Scott Dr Grace Vickers, Chief Executive
Kevin Anderson, Executive Director
Place
Morag Barrow, Joint Director Health and
Social Care and Chief Officer to Midlothian
Integration Joint Board
David Gladwin, Chief Financial
Officer and Section 95 Officer
Saty Kaur, Chief Officer Corporate
Solutions 
Derek Oliver, Executive Director
Children Young People and
Partnerships (Acting)
Duncan Stainbank, Chief Internal Auditor
Alan Turpie, Legal and Governance
Manager and Monitoring Officer Elaine Greaves, Principal Internal Auditor
Gary Thomson, Senior Finance
Business Partner
Katie Gibson, Audit Scotland
Nicola Thorburn, Democratic
Services Team Leader 
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1. Welcome and Apologies for Absence 
The Chair welcomed everyone to the meeting of the Audit Committee. 
No apologies were received.
2. Order of Business 
The Order of Business is as per the agenda. 
3. Declarations of interest 
No declarations of interest were intimated at this stage of the proceedings. 
4. Minute of Previous Meeting
4.1 The Minutes of the previous meeting, held on 30 September 2025, were
submitted for approval and unanimously approved as a correct record.
4.2 Audit Committee requested an update on both items on the action log and that
commentary is added. 
Action 1 – The Executive Director Place advised that there were no colleagues
from Heath & Social Care currently in the meeting and that an update would be
circulated by email. 
Action 2 – The Executive Director Children Young People and Partnerships
(Acting) advised that this information has been requested and will be provided
ahead of the next meeting of the Audit Committee in February 2026. 
5.      Public Reports 
Report No. Report Title Submitted by:
5.1 Treasury Management Mid-Year
Review Report
Chief Financial Officer
and Section 95 Officer
Outline of report and summary of discussion
The Chief Financial Officer and Section 95 Officer presented the report which
informs Members of the Audit Committee, and subsequently Council, of the
Treasury Management activity undertaken during the first half of 2025/26 and the
forecast activity for the second half of 2025/26 in accordance with the Treasury
Management and Annual Investment Strategy approved by Council on 25 February
2025. It also provides an update to the Treasury and Prudential Indicators for
2025/26. 
The Audit Committee were invited to comment on this report before it is presented
to Council. Audit Committee should note the following recommendations which are
proposed to be put to Council on 16 December 2025: - 
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a) Note the report and the treasury activity undertaken in the period to 20
November 2025, as outlined in Section 4 and Section 5.2.
b) Note the current economic position and forecast for interest rates, and the
actual and forecast Treasury Management activity during the second-half of
the year as outlined in Section 5.2 and 5.3; and note the continuation of a
Treasury Management strategy of minimising cash (fixed term deposit)
balances to allow the Council to continue to defer costs associated with
locking into longer-term borrowing at rates that remain elevated, noting that
this strategy is similar to the majority of other Scottish Councils;
c) Note the technical revisions to the Prudential Indicators in Section 6 of this
report.
d) Note the loans fund rate performance relative to other Scottish Local
authorities, as outlined in Section 7, and the cash saving (compared to the
Scottish Average) that the Treasury Management function brings to support
the Council’s in-year revenue budget. 
The Chair thanked for Chief Financial Officer and Section 95 Officer for their report
and invited questions. 
Councillor Parry and the Executive Director Joint Director Health and Social Care
and Chief Officer to Midlothian Integration Joint Board (MIJB) joined the meeting at
11:06am. 
Following the repayment of the Public Works Loan Board (PWLB) loan to the UK
Debt Management Office Councillor Smaill asked where the one-off discount of
£1.079million is accounted for.  The Chief Financial Officer and Section 95 Officer
advised that there are several options on what to do with this money and these are
being carefully explored before being presented to Council in Quarter 3. 
Councillor Smaill also asked when the Council are going to reach their borrowing
limit and what happens at that point.  Councillor Smaill noted that this year, and
prior years, the Council has not built its assets as quickly as expected so therefore
borrowing is currently below the authorised limit.  The Chief Financial Officer and
Section 95 Officer advised that the borrowing strategy is being presented on an
annual basis, and it is at that point where discussion would be had on the borrowing
limits and the flexibility of borrowing to ensure that both Council and Audit
Committee are comfortable with the position. The Chief Financial Officer and
Section 95 Officer added that it is unlikely that we would reach the borrowing limits
as they are always ahead with having the strategy in place.   
Audit Committee thanked and congratulated the Chief Financial Officer and Section
95 Officer, the Senior Finance Business Partner and their teams for a great report
and a job well done. 
Councillor Smaill highlighted that Hillend is currently doing very well and queried
whether this asset should be revalued in terms of fair value principals which may
attract lenders to the Council and whether any of the preparatory expenses from
Hillend require to be written off.  The Chief Financial Officer and Section 95 Officer
advised that the value of Hillend, and indeed any asset the Council hold is revalued
on an annual basis through the capital accounting.  The costs that are chargeable
to the capital programme are determined by the Local Authority Account Code of
Practice and at this point there are none that need written off against the revenue
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account, but this may come in the next stage of the Hillend development. In terms
of future borrowing, in a Local Authority context, that is something that can be done
if we are creating or improving an asset so that flexibility already exists.   
Councillor McCall highlighted that it was positive to see an advert for Hillend running
on prime-time television which will increase the visitors coming to Midlothian. 
The Chair added that they take comfort that Hillend is now starting to make a return
on the investment. 
Decision
Audit Committee noted the report and its recommendations. 
Report No. Report Title Submitted by:
5.2 Internal Audit Work to November
2025
Chief Internal Auditor
Outline of report and summary of discussion
The Chief Internal Auditor presented the report for decision, providing Members of
the Audit Committee with details of the recent work carried out by Internal Audit and
the findings and recommended audit actions agreed by Management to improve
internal controls and governance arrangements. 
The Internal Audit Annual Plan 2025/26 was approved by the Audit Committee on
24 February 2025. Internal Audit has carried out work associated with the delivery
of the plan to meet its objective of providing an opinion on the efficacy of the
Council’s risk management, internal control and governance. 
An Executive Summary of the final Internal Audit assurance report issued, including
audit objective, findings, good practice and recommendations (where appropriate),
and the Chief Internal Auditor’s independent and objective opinion on the adequacy
of the control environment and governance arrangements within each audit area is
shown in Appendix 1. 
The Internal Audit function conforms to the professional standards as set out in
Global Internal Audit Standards (GIAS) including the production of this report to
communicate the results of the reviews. 
The Audit Committee is asked to: 
a) Consider the Executive Summary of the final Internal Audit assurance report
issued associated with the delivery of the approved Internal Audit Annual
Plan 2025/26. 
b) Note the Internal Audit Consultancy and Other Work carried out in
accordance with the approved Internal audit Charter; and 
c) Acknowledge the assurance provided on internal controls and governance
arrangements in place for the areas covered by this Internal Audit work. 
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The Chair thanked for Chief Internal Auditor for their report and appreciated that
they would not have taken the decision lightly to advise that these are providing
limited assurance as this determines that there are significant gaps, weaknesses
and non-compliance. 
The Chair invited questions. 
Councillor Milligan highlighted a statement within the report that states that the
Council do not have an existing Home to School Transport policy. Councillor
Milligan added that they find this impossible to believe as they have seen many
reports being presented in relation to changing this policy. This is not a new subject;
the budget has been overspending by almost £1millon per year for the last few
years to the extent where Officers were asked to revisit this year’s budget to
increase the Home to School Transport budget by £1million.  Councillor Milligan
requested an explanation. 
The Chief Internal Officer advised there is a Home to School Transport policy in
place now and that this was approved by Council in May 2025.  For the period prior
to that, Internal Audit were not provided with a Home to School Transport policy
and were unable to establish if there was a policy in place for mainstream school
transport.  There was a policy in place for Adult Social Care. 
Councillor Milligan referred to the Senior Officers attending the meeting today for
further information and confirmation if there was a policy in place prior to May 2025
and whether this was just not provided to Internal Audit.  The Chair agreed and
invited Officers to respond. 
The Executive Director Children Young People and Partnerships (Acting) advised
that, in terms of their previous post as the Chief Officer Place for the Travel and
Transport Team, there were processes in place to deliver Home to School
Transport and that they can review and confirm the position on the Home to School
Transport policy and what was reported to Internal Audit. 
The Executive Director Place advised that there is now a definitive policy in place
and what we did not have previously was any set criteria in terms of eligibility.  The
transport provision was based on referrals that the Travel and Transport Team
received, and eligibility was not questioned, which is a failing that has been picked
up as part of this audit and processes have been tightened since.  In terms of
eligibility, this is now filtered through colleagues in Education to be clear of what
type of transport is provided – this process was in place this year and has been
smoother than previous years however there are some anomalies where all the
details are not available. 
The Chief Executive confirmed Officers will collate the information on policies,
procedures and guidelines that were in place prior to the policy being agreed in
May 2025 and present to the Client Transport Cross Party Working Group to
demonstrate what has been in place.   
The Chair thanked the Chief Executive and queried if any of this information had
already been shared with Internal Audit. 
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The Chief Internal Auditor advised that this will have been provided to Internal Audit,
however Officers will check Internal Audit has all information. 
Councillor Milligan still felt that there was a lot of missing information and
unanswered questions.  For example, how would the Travel and Transport Team
know if someone was eligible for provision. This should have been the responsibility
of Education or Social Work Departments.   
The Chief Internal Audit added that there are also legislative requirements that the
Council has over transporting children which were in place and being adhered to. 
Councillor Bowen agreed with the sentiments expressed by Councillor Milligan and
asked if Home to School Transport had been dealt with by Audit Committee
previously.  The Chair advised that the investigation by Audit Committee and
Internal Audit was generated by the significant overspend in a short period of time. 
The Chief Internal Audit added that there was a report presented to Audit
Committee in 2021 however it was light touch and there were no recommendations. 
The report in today’s meeting papers is much more detailed and has been through
all the controls.   
Councillor Smaill added that the Conservative Group investigated the Home to
School Transport issue in detail around 7 years ago and were advised that it was
all procured under the normal rules of the Council and that there was a statutory
obligation. Councillor Smaill highlighted some of the billing issues with
unscrupulous suppliers and asked if there was any recovery action that could be
taken.  Additionally, Councillor Smaill asked if there was a certain point where a
child does not need a taxi to school.  The Chief Financial Officer and Section 95
Officer advised that if the Council has overpaid for a service there is an option to
chase this or seek recompense. The Chief Financial Officer and Section 95 Officer
added that there have been many lessons learned and that we were in a different
place for 2025/26.  This year's figures are based on comprehensive information and
are posted with a degree of accuracy. Councillor Smaill added that the problem in
seeking recompense for overpayment to suppliers is that the information we hold
is not complete.  Councillor Smaill suggested that, if overpayments had been made,
then discussions on future contracts with those suppliers should take this into
consideration.   
The Chief Internal Auditor added that in terms of over payments, recovery has been
made from the instance that was reported by a parent, and the supplier is no longer
on those routes. Contracts are in place from 2025, and the invoicing now flows from
the providers. As part of the control process, these must be received in a timely
manner to allow the Chief Financial Officer and Section 95 Officer to include these
in the financials.   
The Chair queried why invoices with no route numbers are being authorised for
payment. The Chief Internal Auditor advised that the Education Team created a
database to reconcile the incoming invoiced, however this had not been shared
with Finance.  This information sharing is now in place, and it is the intention of
Internal Audit to revisit this in 2026 and provide further reassurance to the Audit
Committee. 
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Councillor Smaill asked why things started to change and go wrong in relation to
Home to School Transport when it did. The Chief Internal Audit advised that there
were 4 significant reasons for the increases in costs in the 2024/25 financial year;
(i) a general inflationary increase, (ii) in August 2024 the time of the school day was
changed and all secondary schools in the authority started and finished at the same
times which led to an increase in busses required, (iii) in January 2025 the decision
was taken to close Mayfield Primary School and transport the children to the
alternative school and (iv) there was a significant increase in the Additional Support
Needs (ASN) population of pupils being transported.   
Councillor Milligan added that this report, and what has been discussed, is a
damning indictment of the Council’s ability to deliver within budget.  The lack of
policy, the lack of clarity on authorisation procedures, a budget that has been
overspent by £1million for years, no investment in appropriate software solutions
for pupil transport, financial information not flowing appropriately and the lack of
resources were highlighted by Councillor Milligan as being noted in the report as
contributing factors to this issue.   
Councillor Milligan reminded Audit Committee that Council put an additional
£1million in the 2025/26 budget to get a balanced budget for Home to School
Transport.  The reports now show a further £900,000 overspend despite us being
in a different place as per the Chief Financial Officer and Section 95 Officer’s
update.  Councillor Milligan is unclear on how this can continue to be overspent and
asked what Officers are doing to investigate and manage this, particularly now that
there is a policy in place.  This is a front-line service that is fluid and therefore should
have the most in-depth oversight by the Senior Management Team, Audit, Legal
and Finance.  Councillor Milligan added that the information being provided to the
18 Elected Members does not contain enough detail to allow them to do their job. 
The Chief Financial Officer and Section 95 Officer advised that for the 2025/26
budget, £1million was added but that was based on the figures that Finance were
working with from 2024/25, recognising that costs were well out with budget and to
set a reasonable balanced budget they needed to add a significant amount of cost.
The Chief Financial Officer and Section 95 Officer explained that this decision was
taken in advance of knowing the end position for 2024/25, and as the audit report
shows, this was discussed at Council in June 2025 and some of the meetings prior
to that. There was a significant unknown cost that came through in the last quarter
of 2024/25 that was not included when the budget was set and therefore not
considered, this equated to approximately £700,000.  If the Finance Team had been
aware of the £700,000 when the budget was set, they would have added £1.7million
rather than £1million.  The figures being projected for the current financial year are
£200,000 more than that therefore for 2025/26 they have only seen a cost increase
of that amount based on the actuals from 2024/25. 
Councillor Milligan acknowledged why the £1million was added and that it had been
a continuation from previous years and therefore it was prudent to add that.  Elected
Members had explained that the additional £700,000 was a result of not having a
good management system, insufficient oversight and no policy in place. Councillor
Milligan highlighted that, at a meeting of the Business Transformation Steering
Group (BTSG), Elected Members asked that the budget be realigned due to the
continued overspend as they assumed Officers had done all they could to check
the spend could be brought back into line.  Councillor Milligan stated they were
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unclear on why there is continued overspend when there is now a policy in place
and asked at what stage it is recognised that this budget is out of control. 
The Joint Director Health and Social Care and Chief Officer to Midlothian
Integration Joint Board left the meeting at 11:51am. 
The Chief Internal Auditor advised that, in terms of going forward with Home to
School Transport, this audit takes us to a point where there is a base level of a
control environment which means Officers will have the information in the correct
format to make defined policy choices and will also support Elected Members
making informed decisions.  The authorisation process is in place regarding ASN
however a review may be required regarding eligibility.   
The Chair asked that Internal Audit are fully engaged with Home to School
Transport going forward and asked that a report is brought to Audit Committee
annually.  The Chief Internal Auditor also agreed to attend the Cross Party Working
Group. 
Councillor Milligan reiterated that this is a front-line demand-led service which
requires the highest level of oversight to monitor mistakes or any potentially
fraudulent activity. 
The Chief Executive added that, as the Chief Internal Auditor advised, the policy
had been implemented in line with statutory requirements but highlighted that the
Scottish Government have school transport guidance and suggested that a
mapping exercise is undertaken to ensure policy, guidance and governance are
aligned and include an analysis of the demographic.  It was agreed that this deeper
dive should be captured at the Client Transport Cross Party Working Group and a
quarterly update on the spend be reported to Audit Committee.     
The Chair agreed and highlighted that they do not want to see services withdrawn
but we must ensure the service is being delivered to the correct people.  Councillor
Smaill agreed and suggested that eligibility should be reviewed annually as not all
ASN people will require transport. 
Councillor Milligan stressed that this budget must be brought back inline to avoid
cuts to other critical services.  Councillor Milligan asked if transport operators are
registered to take payments under the new contracts and whether young people,
who are entitled to free bus travel, could use their bus passes. 
Councillor McCall added that offering parents mileage and having buses for
outlying areas to maximise use could be considered as ways to reduce costs. 
Councillor McCall appreciated that it is not easy for some young people with ASN
to share transport, but it is something that could be looked at. 
The Chief Internal Audit Officer assured Audit Committee that a lot of the ideas
shared during today’s meeting are being explored by the project board and that
having the control measures in place allows informed decisions to be made. 
The Chair noted that today’s discussion had briefly covered the Foster Care and
Adoption report. The Chief Internal Auditor advised that the service is currently
following up on all the recommendations to bring it under control.
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The report was moved by Councillor McCall, seconded by Councillor Smaill. 
Decision
Audit Committee approved the report and the recommendations. 
Action
Collate the information on policies, procedures and guidelines that were in place
prior to the Home to School policy being agreed in May 2025 and present to the
Client Transport Cross Party Working Group to demonstrate what has been in
place – Chief Executive and Executive Director Children Young People and
Partnerships (Acting). 
Extend an invitation to the Client Transport Cross Party Working Group to the
Chief Internal Auditor – Democratic Services. 
Request that the Client Transport Cross Party Working Group undertake a
mapping process to ensure policies, procedures and guidance are aligned to
those of the Scottish Government – Client Transport Cross Party Working Group. 
Provide a quarterly update on the budget spend on Home to School Transport -
Chief Financial Officer and Section 95 Officer. 
Report No. Report Title Submitted by:
5.3
Follow-Up Review of Completed
Internal Audit Recommendations
and Progress Update
Chief Internal Auditor
Outline of report and summary of discussion
The Chief Internal Auditor presented the report for decision, providing an update to
Members of the Audit Committee on the results of the Internal Audit Follow-up
review which included a sample check on the adequacy of new internal controls for
Internal Audit recommendations marked as completed by Management in the
period August 2024 to September 2025. 
This report also provides an update to members of the Audit Committee on the
status of the implementation by Management of audit recommendations made and
agreed in Internal Audit reports. 
Internal Audit is an independent appraisal function established for the review of the
internal control system as a service to Midlothian Council. It objectively examines,
evaluates and reports on the adequacy of internal control as a contribution to the
proper, economic, efficient and effective use of resources and the management of
risk. 
The Internal Audit activity adds value to the organisation (and its stakeholders)
when it considers strategies, objectives, and risks; strives to offer ways to enhance
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governance, risk management and control processes (by way of making audit
recommendations); and objectively provides relevant assurance. 
The remit of the Audit Committee includes “To consider reports on the effectiveness
of internal controls and monitor the implementation of agreed actions”, as part of its
high-level oversight of the Council’s governance, risk management and control
framework. 
The Audit Committee is asked to: 
a) Note the results from the sample check of Internal Audit recommendations
that have been marked as completed by Management since the last review
to improve internal controls and
governance, and mitigate risks. 
b) Acknowledge the progress made by Management in implementing Internal
Audit recommendations to improve internal controls and governance, to
mitigate risks, and consider whether it is satisfied with the progress made by
Management. 
c) Considers whether it is satisfied with the outcomes or whether any further
action is required. 
d) Endorse the proposal to extend the due dates for the overdue
recommendations; and 
e) Note that Internal Audit will continue to monitor for completion the
outstanding recommendations and will provide update reports to the Audit
Committee. 
The Chair thanked the Chief Internal Auditor for their report and invited questions. 
Councillor Smaill noted that Internal appear to be much busier than in previous
years and asked if there was sufficient resource in the team.  The Chair asked the
Chief Internal Auditor to ensure Audit Committee are made aware of any resource
or system requirements. 
Councillor Smaill referred to the tables on page 73 and 74 of the meeting papers
and specifically the section on Developer Contributions and Midlothian Energy
Limited (MEL).  The information in the table considers Developer Contributions to
be of high financial value but the rating given is low and for MEL there is a higher
level of scrutiny required. Councillor Smaill asked if these should be rated as high
to match the narrative.  The Chief Internal Auditor acknowledged Councillor Smaill’s
points and advised that for MEL, reporting on this venture does come through Audit
Committee and Council in terms of further recommendations. For Developer
Contributions, discussions are ongoing to determine whether this can be covered
at the Capital Plan & Asset Management Board (CPAMB). 
The report was moved by Councillor McCall, seconded by Councillor Smaill. 
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Decision
Audit Committee approved the report and its recommendations. 
Report No. Report Title Submitted by:
5.4 Strategic Risk Management –
Strategic Risk Profile Quarter 2,
2025-26
Executive Director
Children Young People
and Partnerships (Acting)
Outline of report and summary of discussion
The Executive Director Children Young People and Partnerships (Acting)
presented the report for information, providing Audit Committee with: 
• An update on the risk responses Midlothian Council has implemented during
Q2 2025/26 to respond to the current risk climate. 
• Assurance that Midlothian Council took a proportionate and planned
approach to prepare and respond to the current risk climate. 
• The risk evaluation of current strategic risks and opportunities for the
Council. 
Audit Committee is recommended to: 
• Note the current risk landscape and organisational response to the most
significant risks in Quarter 2, 2025-26 (1st July to 30th September 2025). 
The Chair thanked the Executive Director Children Young People and Partnerships
(Acting) for their report and invited questions. 
Audit Committee noted the strategic risks shown on page 95 of the meeting papers
and queried the climate change evaluation.  The Executive Director Children Young
People and Partnerships (Acting) added that the scoring is complex in term of
likelihood and impact.  Those two parameters themselves are at the highest degree.
Midlothian Council is on course to meet its net-zero target and changing that target
from 2030 to 2045 provides more time and aligns us with the government targets. 
Councillor Smaill highlighted fire risk and suggested that remote sites, such as
Vogrie and Hillend, are added as specific fire risk areas as they are not attended
sites at night. The Executive Director Children Young People and Partnerships
(Acting) advised that, in terms of fire risk assessments and discussion with the
Scottish Fire and Rescue Service in relation to remote sites, they are aware of fire
detection and fire deterrents.  The Executive Director Children Young People and
Partnerships (Acting) acknowledged Councillor Smaill’s point and added that those
sites will be identified in service risk registers however they will consider this for the
Q3 report. 
The Chair highlighted section 3.24 of the report (page 98) and the reference to
Hopefield Industrial Estate.  The Chair asked if this was a marketing exercise to
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determine if the site was still in demand as they understood that this may have been
used for small units and startup businesses.  The Executive Director Children
Young People and Partnerships (Acting) advised that consideration has been given
to this at various governance forums and that work is ongoing so an updated report
will follow.  The Chair asked if this site will be Council owned and run. The Executive
Director Children Young People and Partnerships (Acting) advised that the site will
be owned by the Council, and a paper will be presented with options on how this
could be run. 
Councillor Bowen mentioned the Scottish Child Abuse Enquiry, which requires local
authorities to make records from 1930 available, and asked if Midlothian Council
had received any requests. The Executive Director Children Young People and
Partnerships (Acting) advised that, in terms of any claims that come in, the team
are having to look back through the detail.  The recovery is an arduous task, but
the team will pick this up as and when claims come forward.  Councillor Bowen
asked for detail on the frequency and number of requests being received.  It was
agreed that the Executive Director Children Young People and Partnerships
(Acting) would pick this up with Councillor Bowen offline. 
Councillor Smaill asked if there were long term projections for social housing in
Midlothian as there are concerns that reserves may be exhausted due to the
reduction in government funding and the developer contributions not being enough.   
The Executive Director Place advised that the suite of housing papers including the
Strategic Housing Investment Plans (SHIP) were presented to Council in October
2025 and that included projections to 2035.  The Executive Director Place
acknowledged that there was a disruption to the housing programme due to the
reduction in subsidy in prior years and this was reported through Council.  There
has been a full reinstatement following the Scottish Government’s response to the
housing emergency; however Midlothian Council are unable to reinstate every
project that was in the SHIP at that time although elements that were still available
were reinstated.  In terms of the financial modelling, this will be part of the Rent
Setting Briefing which will be delivered to Elected Members in January or February
2026.  The public consultation is currently underway.   
Decision
Audit Committee noted the report and the recommendations. 
6. Private Reports 
No items for discussion. 
7. Date of Next Meeting 
The meeting concluded at 12:35pm. 
The next meeting of the Audit Committee will be held on Monday 23 February 2026 at
11:00am.
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Audit Committee               
Monday 23 February 2026
Item 4.2
Audit Committee Action Log 
No Date of
Meeting
Item No and Title Action Action Owner Expected
completion
date
Comments
1 30
September
2025
5.7 Strategic Risk
Management –
Strategic Risk
Profile Quarter 1,
2025-26
Review the Strategic Risk
Ratings assigned to Care at
Home and provide an
update.
Joint Director
Health and Social
Care and Chief
Officer to
Midlothian
Integration Joint
Board
Complete Recommended for Closure
Risk cause
Internal and External providers of Care at Home services
unable to meet service and quality requirements as a result
of a lack of capacity. 
Risk event
Capacity of Community Support outstripped by demand. 
1. Care at Home business continuity plan complete
2. External commissioning complete and ongoing contract
monitoring in place
3. Weekly provider meetings in place
4. Dynamic management of waiting lists in effort to reduce
community waits 
The likelihood remains at 3 and the impact 4.
Page 17 of 246

Page 18

No Date of
Meeting
Item No and Title Action Action Owner Expected
completion
date
Comments
2 30
September
2025
5.7 Strategic Risk
Management –
Strategic Risk
Profile Quarter 1,
2025-26
Review SRP.RR.22 Cost of
Living Crisis and update
with current data following
changes in the support and
benefits available since
2022.
Executive Director
Children Young
People and
Partnerships
(Acting)
February 2026 This information has been requested and will be provided
ahead of the next meeting of the Audit Committee in
February 2026.
3 2 December
2025
Internal Audit Work
to November 2025
– Home to School
Transport  
Collate the information on
policies, procedures and
guidelines that were in
place prior to the policy
being agreed in May 2025
and present to the Client
Transport Cross Party
Working Group to
demonstrate what has been
in place.   
Chief Executive
and
Executive Director
Children Young
People and
Partnerships
(Acting)
TBC 
4 2 December
2025
Internal Audit Work
to November 2025
– Home to School
Transport  
Extend an invitation to the
Client Transport Cross
Party Working Group to the
Chief Internal Auditor
Democratic
Services
December
2025
Recommended for Closure.
Complete – distribution list and existing meeting invites
updated to include the Chief Internal Auditor.
5 2 December
2025
Internal Audit Work
to November 2025
– Home to School
Transport  
Request that the Client
Transport Cross Party
Working Group undertake a
mapping process to ensure
policies, procedures and
guidance are aligned to
those of the Scottish
Government.
Client Transport
Cross Party
Working Group
June 2026 
Page 18 of 246

Page 19

No Date of
Meeting
Item No and Title Action Action Owner Expected
completion
date
Comments
6 2 December
2025
Internal Audit Work
to November 2025
– Home to School
Transport  
Provide a quarterly update
on the budget spend on
Home to School Transport. 
Chief Financial
Officer and Section
95 Officer
February 2026 
Page 19 of 246

Page 20

Page 20 of 246

Page 21

Midlothian Council
Annual Audit Plan 2025/26
Prepared for Midlothian Council
February 2026
Midlothian Council
Monday 23 February 2026
Item No 5.1
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Page 22

Midlothian Council Annual Audit Plan | 2 
Contents 
Introduction 3
Audit scope and responsibilities 4
Audit of the annual accounts 6
Wider scope audit 12
Best Value audit 14
Reporting arrangements, timetable and audit fee 16
Other matters 19 
Accessibility
You can find out more and read this report using assistive technology on
our website www.audit.scot/accessibility.
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Page 23

Introduction | 3 
Introduction 
Purpose of the Annual Audit Plan
1.  The purpose of this Annual Audit Plan is to provide an overview of the
planned scope and timing of the 2025/26 audit of the Midlothian Council
annual accounts. It outlines the audit work planned to meet the audit
requirements set out in auditing standards and the Code of Audit Practice,
including supplementary guidance. 
Appointed auditor and independence
2.  Claire Gardiner of Audit Scotland has been appointed by the Accounts
Commission as external auditor of Midlothian Council (the council) for the
period from 2022/23 until 2026/27. The 2025/26 financial year is therefore
the fourth of the five-year audit appointment. 
3.  The appointed auditor and the audit team are independent of the
council in accordance with relevant ethical requirements, including the
Financial Reporting Council’s Ethical Standard. This standard imposes
stringent rules to ensure the independence and objectivity of auditors.
Audit Scotland has robust arrangements in place to ensure compliance
with ethical standards. The arrangements are overseen by the Executive
Director of Innovation and Quality, who serves as Audit Scotland’s
Ethics Partner.
4.  The Ethical Standard requires auditors to communicate any
relationships that may affect the independence and objectivity of the audit
team. There are no such relationships pertaining to the audit of the council
to communicate.
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Page 24

Audit scope and responsibilities | 4 
Audit scope and responsibilities 
Scope of the audit 
5.  The audit is performed in accordance with the Code of Audit Practice,
including supplementary guidance, International Standards on Auditing
(UK), and relevant legislation. These set out the requirements for the
scope of the audit which includes: 
• An audit of the financial statements and an opinion on whether they
give a true and fair view and are free from material misstatement. 
• An opinion on statutory other information published with the
financial statements in the annual accounts, namely the
Management Commentary and the Annual Governance Statement.
• An opinion on the audited part of the Remuneration Report. 
• Conclusions on the council's arrangements in relation to the wider
scope areas: Financial Management, Financial Sustainability,
Vision, Leadership, and Governance, and Use of Resources to
Improve Outcomes. 
• Reporting on the council’s arrangements for securing Best Value.
• Providing assurance on the Housing Benefit Subsidy Claim, Non-
Domestic Rates Return, and the Whole of Government Accounts
return. 
• A review of the council’s arrangements for preparing and publishing
statutory performance information. 
• Provision of an Annual Audit Report setting out significant matters
identified from the audit of the annual accounts and the wider scope
areas specified in the Code of Audit Practice.
Responsibilities 
6.  The Code of Audit Practice sets out the respective responsibilities of the
council and the auditor. A summary of the key responsibilities is outlined
below. 
Auditor’s responsibilities
7.  The responsibilities of auditors in the public sector are established in
the Local Government (Scotland) Act 1973. These include providing an
independent opinion on the financial statements and other information
Page 24 of 246

Page 25

Audit scope and responsibilities | 5 
reported within the annual accounts, and concluding on the council’s
arrangements in place for the wider scope areas and to secure Best Value. 
Midlothian council’s responsibilities
8.  The council has primary responsibility for ensuring proper financial
stewardship of public funds, compliance with relevant legislation and
establishing effective arrangements for governance, propriety and
regularity that enables it to successfully deliver its objectives. The features
of proper financial stewardship include: 
• Establishing arrangements to ensure the proper conduct of its
affairs. 
• Preparation of annual accounts, comprising financial statements
that give a true and fair view and other information. 
• Establishing arrangements for the prevention and detection of
fraud, error and irregularities, and bribery and corruption. 
• Implementing arrangements to ensure its financial position is
soundly based. 
• Making arrangements to secure Best Value. 
• Establishing an internal audit function.
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Page 26

Audit of the annual accounts | 6 
Audit of the annual accounts 
Introduction
9.  The audit of the annual accounts is driven by materiality and the risks of
material misstatement in the financial statements, with greater attention
being given to the significant risks of material misstatement. This chapter
outlines materiality, the significant risks of material misstatement that have
been identified, and the impact these have on the planned audit
procedures. 
Materiality
10.  The concept of materiality is applied by auditors in planning and
performing an audit, and in evaluating the effect of any uncorrected
misstatements on the financial statements or other information reported in
the annual accounts. 
11.  Materiality is used to determine whether matters identified during the
audit could reasonably be expected to influence the decisions of users of
the financial statements. Auditors set a monetary threshold when
determining materiality, although some issues may be considered material
by their nature. Therefore, materiality is ultimately a matter of the auditor’s
professional judgement.
12.  The materiality levels determined for the audit of the council and its
group are outlined in Exhibit 1.
Exhibit 1
2025/26 Materiality levels for the council and its group 
Materiality
Midlothian council and its
group 
Materiality – based on an assessment of the needs of
users of the financial statements and the nature of the
council operations, the benchmark used to determine
materiality is gross expenditure based on the audited
2024/25 financial statements. Materiality has been set at
2% of the benchmark.
£11.9 million
Page 26 of 246

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Audit of the annual accounts | 7 
Materiality
Midlothian council and its
group 
Performance materiality – this acts as a trigger point. If
the aggregate of misstatements identified during the audit
exceeds performance materiality, this could indicate that
further audit procedures are required. Using professional
judgement, performance materiality has been set at 70% of
planning materiality.
£8.3 million 
Reporting threshold – all misstatements greater than the
reporting threshold will be reported. 
£0.595 million
Source: Audit Scotland
Significant risks of material misstatement to the financial
statements
13.  The risk assessment process draws on the audit team’s cumulative
knowledge of the council, including:
•  the nature of its operations and its significant transaction streams
•  the system of internal control
•  governance arrangements and processes; and
• developments that could impact on its financial reporting. 
14.  Based on the risk assessment process, significant risks of material
misstatement to the financial statements have been identified and these
are summarised in Exhibit 2. These are the risks which have the greatest
impact on the planned audit approach, and the planned audit procedures
in response to the risks are also outlined in Exhibit 2. 
15.  The risk assessment process is an iterative and dynamic process. The
assessment of risks set out in this Annual Audit Plan may change as more
information and evidence is obtained over the course of the audit. Where
such changes occur, these will be reported to the council and those
charged with governance, where relevant. 
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Page 28

Audit of the annual accounts | 8 
Exhibit 2
Significant risks of material misstatement to the financial statements 
Risk of material misstatement  Planned audit response
Fraud caused by management
override of controls 
Management is in a unique position to
perpetrate fraud because of
management’s ability to override
controls that otherwise appear to be
operating effectively.
The audit team will:
• Evaluate the design and implementation of
controls over journal entry processing.
• Make inquiries of individuals involved in the
financial reporting process about inappropriate
or unusual activity relating to the processing of
journal entries.
• Test journal entries, focusing on those that are
assessed as higher risk, such as those affecting
revenue and expenditure recognition around the
year-end. 
• Evaluate significant transactions outside the
normal course of business.
• Carry out substantive testing of income and
expenditure transactions around the year-end to
confirm they are accounted for in the correct
financial year.
• Conduct focussed testing of accounting accruals
and prepayments.
• Assess the adequacy of controls in place for
identifying and disclosing related party
relationships and transactions in the financial
statements. 
• Assess changes to the methods and underlying
assumptions used to prepare accounting
estimates and assess these for evidence of
management bias.
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Page 29

Audit of the annual accounts | 9 
Risk of material misstatement  Planned audit response
Valuation of property, plant and
equipment 
The council held £1.2 billion of property,
plant, and equipment (PPE) at 31 March
2025, of which £1.1 billion was land and
building assets. 
The council is required to value land
and building assets at existing use value
where an active market exists for these
assets. Where there is no active market,
these assets are valued on a
depreciated cost replacement (DRC)
basis. As a result, there is a significant
degree of subjectivity in these
valuations which are based on specialist
assumptions, and changes in the
assumptions can result in material
changes to valuations.
From 2025/26, CIPFA/LASAAC’s
revised Code introduces HM Treasury’s
reforms, moving local authorities to
quinquennial valuations with annual
indexation applied in intervening years.
The first year of implementation brings
an increased risk of material
misstatement due to the change in
accounting treatment and the new
judgements required, particularly when
selecting appropriate indices to apply.
The audit team will: 
• Evaluate the design and implementation of
controls over the valuation process. 
• Review the information provided to the valuer
and assess this for completeness and accuracy.
• Evaluate the competence, capabilities, and
objectivity of the valuer.
• Obtain an understanding of management’s
involvement in the valuation process to assess if
appropriate oversight has occurred.
• Review the appropriateness of the key data and
assumptions used in the 2025/26 valuation
process, and challenge these where required.
• Review the indices applied by management to
assets not subject to valuation in 2025/26 and
assess if these are reasonable and have been
correctly applied.
Source: Audit Scotland
Key audit matters 
16.  The Code of Audit Practice requires public sector auditors to
communicate key audit matters. Key audit matters are those matters, that
in the auditor’s professional judgement, are of most significance to the
audit of the financial statements and require most attention when
performing the audit. 
17.  In determining key audit matters, auditors consider:
• Areas of higher or significant risk of material misstatement. 
• Areas where significant judgement is required, including accounting
estimates that are subject to a high degree of estimation
uncertainty. 
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Page 30

Audit of the annual accounts | 10 
• Significant events or transactions that occurred during the year.
18.  In addition to the significant risks of material misstatement in Exhibit 2,
the following key audit matters have been identified as part of our planning
process and will be reported on in our Annual Audit Report.
• Pension Valuation: The valuation requires the use of an actuarial
methodology based on a range of assumptions including financial
and demographic assumptions. Small movements in the
assumptions can result in material changes to valuations. We will
assess the scope, independence and competence of the
professionals engaged in providing estimates for pensions and
review appropriateness of actuarial assumptions and results
including comparison with other councils. We will establish officer’s
arrangements for ensuring the reasonableness of professional
estimations and the accuracy of information provided to the actuary
by Midlothian Council.
Group audit
19.  The council is part of a group and prepares group financial
statements. The group is made up of five components, including the
council which is the parent of the group. Risk assessment procedures
have been performed on the group audit to identify if there are any risks of
material misstatement to the group financial statements, or any
components where audit procedures are required for the purposes of the
group audit. The outcome of the risk assessment procedures on the group
audit are outlined in Exhibit 3.
Exhibit 3
Outcome of risk assessment procedures on the group audit 
Group
component 
Accounting
treatment
Risk of material
misstatement 
Audit
procedures
required
Auditor 
Midlothian
Council 
(Parent)
Consolidated on
a line-by-line
basis
Yes – Exhibit 2 Yes – full scope
audit
Audit Scotland
Trusts,
bequests,
common good
community
funds
(Subsidiary)
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
Audit Scotland
Page 30 of 246

Page 31

Audit of the annual accounts | 11 
Group
component 
Accounting
treatment
Risk of material
misstatement 
Audit
procedures
required
Auditor 
Lothian
Valuation Joint
Board
(Associate)
Accounted for
on equity basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
Audit Scotland
Midlothian
Integration Joint
Board (Joint
Venture)
Accounted for
on equity basis
No – not material
to the group
financial
statements 
Group level
analytical
procedures only
Audit Scotland
Midlothian
Energy Ltd
(Joint Venture)
Accounted for
on equity basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
PWC
Source: Audit Scotland
Page 31 of 246

Page 32

Wider scope audit | 12 
Wider scope audit 
Introduction
20.  Reflecting the fact that public money is involved, the Code of Audit
Practice requires that public audit is planned and undertaken from a wider
perspective than in the private sector. The wider scope audit set out by the
Code of Audit Practice broadens the audit of the annual accounts to
include consideration of additional aspects or risks in four wider scope
areas, which are summarised below: 
• Financial Management – this means having sound budgetary
processes. Factors that can impact on the council being able to
secure sound financial management include the strength of the
financial management culture, accountability, and arrangements to
prevent and detect fraud, error and other irregularities, bribery and
corruption. 
• Financial Sustainability – this means looking forward over the
medium and longer term in planning the services to be delivered
and how they will be delivered effectively. This is assessed by
considering the council’s medium to longer-term planning for
service delivery. 
This area remains a significant business risk across the local
government sector for all councils including Midlothian, especially in
the longer term. This area is being actively managed by the council
with appropriate financial plans in place which are subject to regular
review. We will continue to review and assess the arrangements in
place at the council to ensure operations are financially sustainable.
• Vision, Leadership and Governance – this means having a clear
vision and strategy, with set priorities within the vision and strategy.
This is assessed by considering the clarity of plans in place to
deliver the vision and strategy and the effectiveness of the
governance arrangements to support delivery.
• Use of Resources to Improve Outcomes – this means using
resources to meet stated outcomes and improvement objectives
through effective planning and working with partners and
communities. This is assessed by considering the council’s
arrangements for ensuring resources are deployed to improve
strategic outcomes, meet the needs of service users, and deliver
continuous improvement.
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Page 33

Wider scope audit | 13 
21.  A conclusion on the effectiveness and appropriateness of
arrangements the council has in place for each of the wider scope areas
will be reported in the Annual Audit Report.
Significant wider scope risks
22.  No significant risks in the wider scope areas were identified from the
risk assessment process. 
Local Area Network
23.  Each council has a local area network (LAN) comprising of
representatives from relevant scrutiny bodies. The LAN is responsible for
sharing information and intelligence between scrutiny bodies. As part of
the risk assessment process, the audit team have met with the LAN to
share insights and intelligence on strengths and weaknesses facing the
council. No additional significant risks were identified from discussions.
Page 33 of 246

Page 34

Best Value audit | 14 
Best Value audit 
Introduction
24.  Under the Code of Audit Practice, the audit of Best Value in councils is
fully integrated within the annual audit. As part of the annual audit, auditors
are required to take a risk-based approach to assessing and reporting on
whether the council has made proper arrangements for securing Best
Value, including follow up of findings previously reported in relation to
Best Value.
Best Value thematic review 4: Asset Management
25.  The Accounts Commission also reports nationally on thematic aspects
of councils’ approaches to, and performance in, meeting their Best Value
duties. As part of the annual audit, thematic reviews, as directed by the
Accounts Commission, are conducted on the council. 
26.  The thematic review for 2025/26 is on the subject of asset
management and involves considering how the council is managing its
assets to ensure high quality services whilst also responding to the
challenges around financial sustainability and climate change.
Conclusions and judgements on the thematic review will be reported in a
separate Management Report and summarised in the Annual Audit
Report, where required.
27.  At least once over the five-year appointment, the Controller of Audit
will report to the Accounts Commission on the council’s performance in
meeting its Best Value duties. Midlothian Council is included in the fourth
year of the programme.
Statutory Performance Information 
28.  Auditors have a statutory duty to satisfy themselves that councils have
made proper arrangements for preparing and publishing statutory
performance information in accordance with the Statutory Performance
Information Direction 2024 (the Direction) issued by the Accounts
Commission. The outcome of this will be reported in the Annual Audit
Report, which will include: 
• A conclusion on the council’s arrangements for preparing and
publishing the statutory performance information. 
• Any instances where the arrangements or reporting are not in
accordance with the Direction. 
• Areas where the arrangements require to be improved. 
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Page 35

Best Value audit | 15 
29.  In addition, the Accounts Commission requires auditors to include a
summary of Local Government Benchmarking Framework (LGBF)
indicators that the council has reported in the Annual Audit Report. 
Significant Best Value risks
30.  No significant Best Value risks were identified from the risk
assessment process. Audit work on the wider scope areas will help
support conclusions around Best Value.
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Page 36

Reporting arrangements, timetable and audit fee | 16 
Reporting arrangements,
timetable and audit fee 
Audit outputs
31.  The outputs from the 2025/26 audit include: 
• This Annual Audit Plan.
• An Independent Auditor’s Report to the council and the Accounts
Commission setting out opinions on the annual accounts. 
• A Best Value Thematic Report (BV4) Asset Management and how
well the council is managing its assets to achieve corporate
priorities, the changing needs of its population and net zero targets.  
• An Annual Audit Report to the council and the Accounts
Commission setting out significant matters identified from the audit
of the annual accounts, conclusions from the wider scope and Best
Value audit, recommendations, where required, and any good
practice identified. 
32.  The matters to be reported will be discussed with the relevant senior
officers of the council for factual accuracy before they are issued. All
outputs from the audit will be published on Audit Scotland’s website, apart
from the Independent Auditor’s Report, which is included in the audited
annual accounts.  
33.  Target dates for the audit outputs are set by the Accounts
Commission. In setting the target dates for the audit outputs, consideration
is given to the statutory date for approving the annual accounts, which is
30 September 2026 for local government bodies.  
34.  The Independent Auditor’s Report and Annual Audit Report are
planned to be issued by the target date of 30 September 2026.
Audit timetable
35.  Achieving the timetable for production of the annual accounts,
supported by complete and accurate working papers, is critical to delivery
of the audit to agreed target dates. Exhibit 4 includes a timetable for the
audit, which has been agreed with management. Agreed target dates will
be kept under review as the audit progresses, and any changes required,
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Page 37

Reporting arrangements, timetable and audit fee | 17 
and their potential impact, will be discussed with the council and reported
to those charged with governance, where required. 
Exhibit 4
2025/26 audit timetable 
Audit activity
Midlothian
council target
date
Audit team
target date
Audit
committee date
Issue of Annual Audit Plan N/A 31 March 2026 23 February 2026
Annual Accounts:   
• Consideration of unaudited
annual accounts by those
charged with governance
30 June 2026 N/A  15 June 2026
• Submission of unaudited
annual accounts and all
working papers to audit team
1 July 2026 N/A N/A
• Latest date for audit clearance
meeting
31 August 2026 31 August 2026 N/A
• Issue of draft Letter of
Representation, proposed
Independent Auditor’s Report,
and proposed Annual Audit
Report
N/A 16 September
2026
Date TBC
• Agreement of audited and
unsigned annual accounts
30 September
2026
30 September
2026
Date TBC
• Approval by those charged
with governance and signing
of audited annual accounts 
30 September
2026
30 September
2026
15 September
2026 
• Signing of Independent
Auditor’s Report and issue of
Annual Audit Report 
30 September
2026
30 September
2026
Date TBC
Issue of Best Value
Management Report
1 June 2026 1 June 2026 15 June 2026
Certification of Non-Domestic
Rates Return 
31 December
2026
31 December
2026
N/A
Certification of Housing Benefit
Subsidy Claim
31 December
2026
31 December
2026
N/A
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Page 38

Reporting arrangements, timetable and audit fee | 18 
Audit activity
Midlothian
council target
date
Audit team
target date
Audit
committee date
Certification of Whole of
Government Accounts 
31 December
2026
31 December
2026
N/A
Source: Audit Scotland
Audit fee
36.  The council’s audit fee is determined in line with Audit Scotland’s fee
setting arrangements. The proposed audit fee for the 2025/26 audit is
£308,310 (2024/25: £295,490).
37.  In setting the audit fee, it is assumed that the council has effective
governance arrangements in place and the complete annual accounts will
be provided for audit in line with the agreed timetable. The audit fee
assumes there will be no significant changes to the planned scope of the
audit. Where the audit cannot proceed as planned, for example, due to
incomplete or inadequate working papers, the audit fee may need to be
increased.
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Page 39

Other matters | 19 
Other matters 
Internal audit
38.  The council is responsible for establishing an internal audit function as
part of an effective system of internal control. As part of the audit, the audit
team will obtain an understanding of internal audit, including its nature,
responsibilities, and activities. 
39.  While internal audit and external audit have differing roles and
responsibilities, external auditors may seek to rely on the work of internal
audit where it is considered appropriate. A review of internal audit’s
2025/26 audit plan was carried out to identify if there were any areas
where the audit team could rely on its work. The audit team concluded it
will not rely on internal audit’s work. However, the audit team will review
internal audit's reports and assess if there is any impact on the audit.
Audit quality 
40.  Audit Scotland is committed to the consistent delivery of high-quality
audit. Audit quality requires ongoing attention and improvement to keep
pace with external and internal changes. Details of the arrangements in
place for the delivery of high-quality audits is available from the Audit
Scotland website.
41.  The International Standards on Quality Management (ISQM)
applicable to Audit Scotland for 2025/26 audits are:
• ISQM (UK) 1, which deals with an audit organisation’s
responsibilities to design, implement, and operate a system of
quality management (SoQM) for audits. Audit Scotland’s SoQM
consists of a variety of components, such as governance
arrangements and culture to support audit quality, compliance with
ethical requirements, ensuring Audit Scotland is dedicated to high-
quality audit through engagement performance and resourcing
arrangements, and ensuring there are robust quality monitoring
arrangements in place. Audit Scotland carries out an annual
evaluation of its SoQM and has concluded it complies with this
standard. 
• ISQM (UK) 2, which sets out arrangements for conducting
engagement quality reviews, which are performed by senior
management not involved in an audit, to review significant
judgements and conclusions reached by the audit team, and the
appropriateness of proposed audit opinions on high-risk audits. 
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Page 40

Other matters | 20 
42.  To monitor quality at an individual audit level, Audit Scotland carries
out internal quality reviews on a sample of audits. Additionally, the Institute
of Chartered Accountants of England and Wales (ICAEW) carries out
independent quality reviews on a sample of audits.
43.  Actions to address deficiencies identified by internal and external
quality reviews are included in a rolling Quality Improvement Action Plan,
which is used to support continuous improvement. Progress with
implementing planned actions is monitors on a regular basis by Audit
Scotland’s Quality and Ethics Committee.
44.  Audit Scotland may periodically seek the views of the council on the
quality of audit services provided. The audit team would also welcome
feedback at any time.
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Page 41

Midlothian Council
Annual Audit Plan 2025/26 
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500  
www.audit.scot 
AS.5.0
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Page 42

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Page 43

Audit Committee
Monday 23 February 2026
Item No 5.2 
Local Government in Scotland - Financial Bulletin 2024/25 
Report by David Gladwin, Chief Finance Officer and Section 95 Officer 
Report for Information 
1 Recommendations 
Audit Committee is recommended to:
• Consider the Audit Scotland report; and
• Note that the key messages have been considered by Council
Officers and are either embedded in the Medium Term Financial
Strategy (MTFS) Report to be considered by Council on
Tuesday 24th February or in plans for future iterations of the
MTFS. 
2 Purpose of Report / Executive Summary 
The purpose of this report is to provide Audit Committee with a
summary of the Local Government in Scotland Financial Bulletin
2024/25 report which was published by Audit Scotland in January 2026
and is appended to this report. 
Four main messages come from the report covering revenue funding,
budget gaps, use of reserves in addressing budget gaps, delivery of
savings capital investment and financial sustainability. 
Date Friday 6th February 2026 
Report Contact:
David Gladwin, Chief Financial Officer and Section 95 Officer
David.Gladwin@midlothian.gov.uk 
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Page 44

3 Background 
3.1 Audit Scotland is a statutory body established in 2000, under the Public
Finance and Accountability (Scotland) Act 2000. It provides services to
the Auditor General for Scotland and the Accounts Commission for
Scotland. 
3.2 Audit Scotland has prepared the appended report “Local Government
in Scotland Financial Bulletin 2024/25” for the Auditor General for
Scotland. The Auditor General appoints auditors to Scotland’s central
government and NHS bodies; examines how public bodies spend
money; helps them to manage their finances to the highest standards;
and checks whether they achieve value for money. 
3.3  The report sets out the challenges and risks that are impacting on the
finances of local Councils with recommendations on how these should
be managed and reported. 
Key Messages 
3.4 Some of the key messages contained in the report are:
• In 2024/25 councils’ total revenue and income increased in real
terms but despite this councils remained reliant on identifying
savings, which becomes progressively more difficult year-on-year,
and again used reserves to balance their budgets.
• Despite being largely successful in implementing the actions agreed
to manage budgets, with around 90% of savings targets delivered,
the sector reported a collective overspend against their agreed
revenue budgets for the first time in six years.
• Most councils spent less than planned on capital projects and were
relying more on borrowing to finance expenditure in the face of
reductions in capital funding. Councils continue to borrow more to
enable investment in their estates and council debt, and annual
interest costs, continue to increase.
• There are increasing indications that councils are struggling
financially. Costs continue to outpace funding increases, and there
remain significant commitments on funding to fulfil both statutory
duties and national policy commitments.
• Councils need to take urgent action to address the sustained and
recurring cost pressures associated with delivering services. This
will mean carefully considering where services need to be reduced;
how service delivery can be fundamentally reconfigured; who is
eligible to receive services; and policies on fees and charges. 
3.5 Recommendations are contained on page 6 of the report and listed
below in table 1 with an initial self-evaluation on the Council’s position
against them. 
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Table 1: Report Recommendations and Initial Self-Assessment 
Recommendation Self-evaluation
Councils must continue to improve the
clarity and comprehensiveness of their
reporting on savings performance
within their management
commentaries, including the provision
of comparisons to targets agreed during
budget-setting and whether savings
made were recurring or non-recurring.
Management commentary contains
information on savings but narrative will be
reviewed with the aim of sharpening it up
thus improving visibility to the reader.
Councils should clearly explain within
their management commentaries, and
within reports to elected members, how
future revenue budgets will be impacted
by investment decisions and capital
underspends.
Capital investment or monitoring reports
contain details of revenue consequences
in MTFS projections. Work will continue to
ensure they are clear to decision makers.
Ensure that their longer-term capital
investment plan, and the impact that
capital underspending, programme
slippage and changes to overall
indebtedness arising from accounting
changes have had on their overall
financial position, is reported clearly
and in a timely manner to elected
members
This is embedded in routine regular
reporting to elected members both at
Council and at Audit Committee. Longer-
term capital plans will continue to be
developed, refined and improved.
Ensure that reserves policies are
current and remain fit for purpose, and
that where agreed minimum reserves
levels are breached, or forecast to be
breached, there is a clear and time-
bound plan for recovery.
Reserves policies have been approved by
Council and are applied and managed as
part of ongoing financial reporting.
Financial reports refer to reserves
positions, and these are also covered in
the management commentary.
Continue to work with their appointed
auditors to ensure they produce annual
financial statements in a timely manner,
as the sector continues its recovery to
meet statutory reporting deadlines.
The 2024/25 accounts were completed
and audited within statutory deadlines and
plans for the 2025/26 accounts aim to
continue this. 
Ensure that long-term financial plans
(over five years), that adequately
consider risks to financial sustainability
and include detailed scenario planning,
are in place.
The current MTFS extends to 2028/29.
The intention is to extend projections over
the next term of Council in advance of the
2027 Local Government Elections. Annual
provision of Scottish Government funding
information for Councils places constraints
on the quality of MTFS projections.
Scenario planning in this area has been
developed and will be considered further.
Ensure that assessments of medium-
and longer-term financial sustainability,
including reference to specific
indicators, are a central focus of
reporting to elected members.
MTFS projections are presented to
Members formally during each financial
year with informal engagement,
particularly at the Business Transformation
Steering Group, supporting this. The use
of sustainability indicators needs to be
developed and these will be included in
the next iteration of the MTFS. 
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4 Report Implications (Resource, Digital and Risk) 
4.1 Resource 
None 
4.2 Digital 
None 
4.3 Risk 
None 
4.4 Ensuring Equalities (if required a separate IIA must be completed) 
None 
4.4 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Local Government in Scotland Financial Bulletin 2024/25 
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APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Not applicable 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working 
Hub and Spoke 
Modern 
Sustainable 
Transformational 
Preventative 
Asset-based 
Continuous Improvement 
One size fits one 
None of the above 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
Not applicable 
A.5 Involving Communities and Other Stakeholders 
Not applicable 
A.6 Impact on Performance and Outcomes 
Not applicable 
A.7 Adopting a Preventative Approach 
Not applicable 
A.8 Supporting Sustainable Development 
Not applicable 
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Page 48

Page 48 of 246

Page 49

Local government in Scotland
Financial bulletin
2024/25
Prepared by Audit Scotland
January 2026
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2Local government in Scotland: Financial bulletin 2024/25
Contents
Key facts 3
Key messages 4
Recommendations 6
Introduction 7
1. Council funding and financial performance  9
2. Financial position and outlook 24
Appendix 37
Accessibility
You can find out more and read this report using assistive
technology on our website www.audit.scot/accessibility.
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3Key factsKey facts
Key facts
Funding and budgets
1% Annual real-terms increase in funding from the Scottish Government to all
32 councils in 2024/25
24%
Proportion of Scottish Government revenue funding that was ring-fenced
or directed towards national policy commitments in 2024/25, up from
21 per cent in 2023/24
£542m Budget gap identified by our sample of 28 councils at the start of
2024/25. The 2023/24 comparator for those councils was £744 million
£647m 2025/26 budget gap forecast by all 32 of Scotland’s councils
Financial performance
1% Real-terms increase in 29 councils’ total revenue funding and income in
2024/25 compared to 2023/24
12 out of 29 Councils that reported overspends against their agreed General Fund
revenue budgets
28 out of 30 Councils that reported underspends against their agreed General Fund
capital budgets
23 out of 25 Councils that reported underspends against their agreed HRA capital
budgets
Financial position
£21.9bn
Councils’ net debt in 2024/25, a 13.5 per cent increase since 2023/24.
Councils’ long-term external debt includes £14.9 billion borrowed directly
from the Public Works Loan Board
7% Annual decrease in usable reserves between 2023/24 and 2024/25
16 out of 30 Councils that made unplanned use of reserves in 2024/25
85% Proportion of the General Fund that is committed, a two percentage point
increase from 2023/24
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4Key messages
Key messages
Key messages
Key messages
Despite increased funding in 2024/25, the financial outlook
for Scotland’s councils presents substantial challenges.
The costs of delivering services continues to rise, debt is
increasing, reserve levels are falling and there is continued
reliance on non-recurring measures to close significant
budget gaps. This all raises concerns around councils’
medium-term financial sustainability.
1 In 2024/25, councils’ total revenue funding and income increased
by 1.3 per cent. Despite this, councils faced a £542 million
budget gap and remained reliant on reserves and savings to
balance their budgets. Councils identified around £200 million
of predominantly recurring savings to help manage overall
financial pressures.
2 Despite being largely successful in implementing the actions
agreed to manage budgets, with around 90 per cent of savings
targets delivered, the sector reported a collective overspend
against their agreed revenue budgets for the first time in six
years. Around a third of councils reported that they overspent
against their agreed revenue budgets and many struggled to
deliver recurring savings, instead taking one-off measures to
manage their in-year spending.
3 In 2024/25, most councils spent less than planned on capital
projects but invested around £3.5 billion in both existing and
new public assets. Reduced capital funding meant councils
continued to rely on borrowing to finance increasingly expensive
projects and, alongside changes to how they account for leases,
have seen their total debt increase by over £2.5 billion in a year.
Councils now spend around £1.2 billion a year servicing these
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Key messages 5
4 There are increasing indications that councils are struggling
financially, with a collective budget gap of £647 million identified
when budgets were set for 2025/26. Costs continue to outpace
funding increases, and there remain significant commitments
on funding to fulfil both statutory duties and national policy
commitments. There is also continued reliance on non-recurring
measures, such as using reserves, to address budget gaps
which is simply not sustainable. Technical changes have
contributed to rising debt, but there is also a need to recognise
that borrowing is forecast to increase, and this comes with
associated costs. Councils need to take urgent action to address
the sustained and recurring cost pressures associated with
delivering services. This will mean carefully considering where
services need to be reduced; how service delivery can be
fundamentally reconfigured; who is eligible to receive services;
and policies on fees and charges.
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6RecommendationsRecommendations
Recommendations
In 2026, councils should take action to progress significant
outstanding recommendations from previous years around the
transparency of financial reporting:
• councils must continue to improve the clarity and comprehensiveness of their
reporting on savings performance within their management commentaries,
including the provision of comparisons to targets agreed during budget-setting,
and whether savings made were recurring or non-recurring (paragraph 35)
• councils should clearly explain within their management commentaries, and
within reports to elected members, how future revenue budgets will be
impacted by investment decisions and capital underspends (paragraph 39).
In addition, councils should:
• ensure that their longer-term capital investment plan, and the impact that capital
underspending, programme slippage and changes to overall indebtedness
arising from accounting changes have had on their overall financial position, is
reported clearly and in a timely manner to elected members (paragraph 44)
• ensure that reserves policies are current and remain fit for purpose, and
that where agreed minimum reserves levels are breached, or forecast to be
breached, there is a clear and time-bound plan for recovery (paragraph 53)
• continue to work with their appointed auditors to ensure that they produce
annual financial statements in a timely manner, as the sector continues its
recovery to meet statutory reporting deadlines (paragraph 59)
• ensure that long-term financial plans (over five years), that adequately consider
risks to financial sustainability and include detailed scenario planning, are in place
(paragraph 66)
• ensure that assessments of medium- and longer-term financial sustainability,
including reference to specific indicators, are a central focus of reporting to
elected members (paragraphs 80–83).
We note progress against all the recommendations from our Financial bulletin
2023/24 in the Appendix.
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7Introduction
Introduction
1. This report is part of a series of overview outputs produced by
the Accounts Commission which together provide an independent
overview of financial and operational performance of Scotland’s local
government sector.
2. The report examines council’s financial performance in 2024/25.
The bulletin sets out:
• councils’ funding, income and budget-setting
• councils’ financial management and performance
• councils’ financial position at the end of 2024/25 and the
financial outlook.
3. We will shortly publish a brief supplement analysing the recently
published 2026/27 Scottish Budget and levels of funding to councils. In
spring 2026, we will publish our annual detailed briefing examining the
2026/27 budgets set by councils, including analysis of anticipated budget
gaps, actions to address these, and the decisions made by councils
when setting their budgets.
4. We are also reintroducing checklists for elected members to our
regular annual financial reports. It is increasingly important that elected
members understand the financial pressures facing their own councils,
and the impact these may have on future priorities and service delivery.
The checklist includes a range of questions to consider that are linked to
the content of this report and is designed to support councillors in both
decision-making and the scrutiny of decision-making.
Methodology
5. The primary sources of information for this report are councils’
2024/25 accounts and annual audit reports, a data request issued to
councils in October 2025 and Scottish budget documents.
6. Our findings are based primarily on:
• The 2024/25 annual accounts for 29 councils (15 audited and
14 unaudited). At our December deadline, 2024/25 accounts
were unavailable for three councils (Clackmannanshire, East
Dunbartonshire and Stirling). These councils are not included in our
2024/25 analysis (or comparisons to previous years for analysis
based primarily on accounts).
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Introduction 8
• Supplementary information from 30 councils collected via a data
return issued to council directors of finance and reviewed by
appointed auditors. At our November deadline, a data return was
unavailable for Inverclyde and Stirling councils. We also utilised
elements of data returns previously submitted to us in support
of our Local government budgets 2024/25 briefing and other
more recent reports. Where we use these previous returns, we
have adjusted our sample to reflect the 28 councils that we have
comparable data for across both 2023/24 and 2024/25.
• Our analysis of Scottish Government funding sets out the position
for all 32 of Scotland’s councils. Within this report, we analyse
Scottish Government budget documents up to and including the
2025/26 Autumn Budget Revision (published in October 2025). Due
to the timing of the 2026/27 Scottish Budget, this analysis will be
updated and extended to include the 2026/27 Budget information
within a complementary supplement to this report.
• This year we have also worked to develop our use of balance sheet
information, wider intelligence and indicators developed by CIPFA
directors of finance to better analyse the financial sustainability of
the sector and highlighted specific areas that councillors may wish
to consider when setting their own council’s budget for 2026/27.
7. When looking at trends, we convert some figures to real terms.
This adjusts financial information from past and future years to prices for
the year under review (ie, 2024/25). This is to take account of inflation
so that trend information is comparable. To adjust for inflation, we use
gross domestic product (GDP) deflators, which are published quarterly by
HM Treasury. GDP deflators are the standard approach adopted by both
the UK Government and Scottish Government when analysing public
expenditure.
8. Financial trend data (both capital and revenue) relating to funding,
income or expenditure will generally be shown in real terms. Financial
information from the councils’ accounts’ balance sheets remains
unadjusted. This includes trend analysis on reserves, sources of capital
finance, borrowing and debt. These are not adjusted to real terms as they
are already subject to revaluations within councils’ accounts to reflect
current prices.
9. Throughout the report we refer to timescales in the short term as
1–2 years, medium term as 3–5 years and long term as over five years.
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91. Council funding and financial performance
1. Council funding and
financial performance
Total funding and income increased in 2024/25, but councils
again had to apply a series of measures to bridge
budget gaps.
The Scottish Government increased funding to
councils in 2024/25 and 2025/26
10. Councils are reliant on direct funding from the Scottish Government
which represents around two-thirds of their overall income. Typically,
councils receive a draft single-year funding allocation announced
alongside the Scottish budget, normally in December each year. An
initial settlement is then agreed once the Scottish budget has been
formally approved by the Scottish Parliament. Throughout the year, this
initial settlement is subject to revision, with substantial in-year transfers
provided during the autumn and spring budget revisions.
The Scottish budget
The Scottish Government normally publishes its draft budget in
December, outlining provisional allocations to local government.
For 2026/27, this was delayed to January 2026 due to the timing of
the UK Government’s Budget.
The Accounts Commission will publish a supplement to this report
in February 2026 analysing the initial 2026/27 funding allocation to
local government.
Within the Scottish Government budget, funding for councils is shown as
part of the Finance and Local Government portfolio. Councils, however,
also receive funding from other portfolios, for example the Health and
Social Care and Education and Lifelong Learning portfolios. The local
government settlement shows the totality of this funding.
Transfers from other portfolios are then formally accounted for at a Scottish
Government level during the autumn and spring budget revisions.
Initial funding is also subject to changes as additional funding may become
available to the Scottish Government throughout the year, which may be
allocated to councils. Scottish Ministers may also reprioritise funding from
other portfolios to councils during the year.
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1. Council funding and financial performance 10
11. In 2024/25, the Scottish Government initially provided councils with
£12.5 billion of revenue and capital funding at the draft budget stage
within its Finance and Local Government portfolio. Councils received
£1.5 billion of additional funding and internal transfers (as outlined within
the original local government settlement) at the 2024/25 autumn budget
revision. This included funding to support agreed pay deals for teachers
and social care staff and for councils that agreed to freeze council tax
rates. A further £0.3 billion was then provided to councils as part of the
spring budget revision. The 2024/25 final outturn allocation meant that
funding ultimately increased by one per cent in real terms compared to
the total year-end funding provided in 2023/24.
12. The 2025/26 draft budget saw a further increase within the local
government budget, taking funding to councils to £13.6 billion in cash
terms (£13.2 billion in 2024/25 prices). The 2025/26 autumn budget
revision provided councils with £1.5 billion in additional funding and
planned in-year transfers, meaning total 2025/26 Scottish Government
funding to councils increased by five per cent in real terms from the
same point in the prior year (Exhibit 1, page 11).
13. The Scottish Government published its 2026/27 draft budget in
January 2026, estimating that there is a two per cent real terms increase
in the total funding it is providing to councils. We intend to report on a
further analysis of the draft 2026/27 budget within a supplement to this
report which will publish in February 2026.
The 2026/27 budget process will reflect the recently
agreed Draft Fiscal Framework for Local Government
14. The Verity House Agreement included a commitment to reduce
the level of ring-fenced funding, with the aim to provide councils more
flexibility in how to allocate resources. Councils also receive funding
from the Scottish Government that, although not formally ring-fenced, is
provided with the expectation that it is directed for specific purposes.
15. In 2024/25, the Scottish Government ‘baselined’ several ring-
fenced specific grants into the general revenue grant, including the full
£522 million of the specific revenue grant for early learning and childcare
expansion. While the Scottish Government has fulfilled its commitment
under the Verity House Agreement to reducing ring-fenced funding,
councils still need to direct spending towards specific national policies
and statutory duties, and this limits the discretion councils have over how
to use elements of the GRG. Ring-fenced and directed funding amounted
to £3.2 billion in 2024/25 (24 per cent of the total revenue funding to
councils). This is higher than the 21 per cent of funding that was directed
in 2023/24.
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1. Council funding and financial performance 11
Exhibit 1. 
Scottish Government funding to councils since 2019/20 in real and
cash terms
The Scottish Government has increased funding to councils by four per cent in
real terms between 2019/20 and 2025/26, although funding was higher during the
pandemic due to specific additional funding allocations.
0
4
8
12
16
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26
Autumn Budget
Revision
Final outturn
Cash terms
Real terms –
draft budget
Cash terms –
draft budget
Real terms
£ billion
Additional Covid-19 funding (cash)
£1.3bn £0.5bn
Notes:
1. Real-terms analysis, with financial information adjusted to 2024/25 prices. The draft budget
allocations above do not include transfers from other portfolios outlined within the local government
settlement as they are formally accounted for in the autumn and spring budget revisions.
2. Data for 2025/26 remains provisional and will be subject to further adjustment to show
final outturn.
Source: Scottish Government budget documents
16. The Scottish Government and COSLA published the draft Fiscal
Framework between Scottish Government and Local Government
in October 2025. This reflects a commitment within the Verity House
Agreement to establish a new funding relationship between the
Scottish Government and councils. Key principles underlining the
framework include:
• Simplified funding settlement – Streamline the funding
relationship between the Scottish Government and councils,
with earlier engagement in the budget process to support
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1. Council funding and financial performance 12
• Baselining of specific grants – Further incorporation of ring-
fenced revenue grants into the General Revenue Grant, providing
councils with greater flexibility over local spending priorities.
• Exploration of greater revenue-raising powers – Encourage
further consideration of new ways that councils can generate
additional income to help address financial challenges.
• Multi-year funding settlements – When possible, councils will
receive multi-year funding settlements to support wider strategic
planning.
17. The fiscal framework will formally apply to the 2026/27 Scottish
Government Budget, and we intend to report on how these
commitments have been met within our upcoming supplementary work
on the Scottish budget that will accompany this report.
Total revenue funding and income increased by
1.3 per cent in 2024/25, but income generated from
both council tax and business rates fell in real terms
18. In addition to direct revenue funding from the Scottish Government,
councils receive funding and generate income to support their day-to-day
spending from a variety of other sources. These include council tax and
non-domestic rates (NDR, commonly referred to as business rates), but
also fees and charges for using services and council house rents.
19. Overall, our analysis of 29 councils where 2023/24 and 2024/25
accounts were available shows that revenue funding and income
increased by £0.3 billion in real terms (1.3 per cent). Due to the
‘baselining’ of specific funding into the GRG (paragraph 15), there was a
large annual increase in this funding of around £1 billion (12 per cent), but
this was partially offset by a commensurate reduction in other grants of
around £0.6 billion (16 per cent) (Exhibit 2, page 13).
20. The Scottish Government elected not to make changes to NDR rates
or reliefs in 2024/25. Alongside this, councils agreed to freeze council
tax rates in return for funding from the Scottish Government, with the
Scottish Government estimating this additional funding was equivalent to
a five per cent increase in council tax. These decisions contributed to the
income directly generated from both council tax and NDR failing to keep
pace with inflation and falling in real terms by one per cent and three per
cent respectively.
21. Similarly, despite increasing fees and charges in recent years, as
outlined in Local government budgets 2024/25, Local government
budgets 2025/26 and our recent Spotlight on culture and leisure
services, the associated income generated has failed to keep pace with
inflation and fell by over three per cent in real terms.
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1. Council funding and financial performance 13
Exhibit 2. 
Sources of council revenue funding and income in 2023/24 and 2024/25,
in real terms
There was a large increase in GRG and a reduction in other grants in 2024/25, related
to baselining of funding, but overall, the proportion of funding from different sources
was similar to recent years.
(£0.2bn)
(£0.2bn)
(£1.4bn)
(£1.5bn)
(£1.8bn)
(£1.7bn)
(£2.9bn)
(£2.8bn)
(£8.8bn)
(£9.8bn)
(£3bn)
(£3bn)
(£3.5bn)
(£3bn)
Percentage
0 10 20 30 40 50
Interest receivable and
similar charges
Housing Revenue
Account rent
Customer and client
receipts
Grants (including Scottish
Government and others)
Council tax
Non-domestic rates
General Revenue Grant
1%
7%
8%
16%
13%
14%
40%
1%
7%
8%
13%
13%
14%
45%
2023/24
2024/25
Note: Figures subject to rounding
Source: Councils’ annual accounts 2023/24 and 2024/25
Councils identified £542 million of budget gaps at the
start of 2024/25, and agreed plans to close them
22. Councils set budgets in February and March for the financial year
ahead, based on the initial settlement from the Scottish Government.
At the time of setting their 2024/25 budgets, our sample of 28 councils
identified a cumulative budget gap of around £542 million (£744 million
in 2023/24). This gap represented approximately 3.1 per cent of the total
net cost of services, which was a reduction from 2023/24 (4.6 per cent).
Glasgow’s 2024/25 budget gap was outlier. However, this is due to a
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1. Council funding and financial performance 14
multi-year approach to addressing and reporting on their budget gap. The
council is focused on addressing their three-year cumulative budget gap
to 2026/27 and, as part of their 2024/25 budget, approved savings of
£94 million over the three years to 2026/27, of which £34.7 million relates
to 2024/25 as part of this longer-term plan.
23. A range of actions were identified by these councils to close the
budget gap totalling £553 million (£755 million in 2023/24). Approved
bridging actions were higher than the budget gap due to some
councils identifying actions not only to address gaps, but also to enable
specific spending. Exhibit 3 explains how around three-quarters of
bridging actions included identifying recurring/non-recurring savings,
using reserves and making use of financial flexibilities. Exhibit 4
(page 15) shows the decisions taken by individual councils to address
their budget gaps.
24. In 2023/24, councils indicated they would close 19 per cent of their
collective budget gap by raising council tax. In 2024/25, no councils
raised council tax, reflecting the additional funding made available by the
Scottish Government to support a council tax freeze (paragraph 20).
25. Despite increasing funding and measures taken locally to generate
additional income, councils continue to face increasing costs and
continuing financial pressures. As outlined within Local government
budgets 2025/26, at the start of the current financial year, Scotland’s
32 councils identified budget gaps totalling £647 million. We consider the
financial sustainability of the sector in greater detail within Part 2.
Exhibit 3. 
The bridging actions 28 councils identified in their 2024/25 budgets
Over half of councils’ planned bridging actions were recurring savings and the
use of reserves.
Bridging action
2023/24
£755 million, of which:
2024/25
£553 million, of which:
Recurring savings £261 million (35%) £172 million (31%)
Using reserves £211 million (28%) £141 million (25%)
Non-recurring savings £25 million (3%) £43 million (8%)
Financial flexibilities £69 million (9%) £60 million (11%)
Other measures £189 million (25%) £137 million (25%)
Source: Council data returns for budget bulletins (2024 and 2025) and councils’ annual accounts
2024/25 (audited and unaudited)
Between 2020 and
2024, the Scottish
Government permitted
councils to make use
of a range of financial
flexibilities to manage
financial pressures.
One of these related to
service concessions,
including Public
Private Partnerships
(PPPs), and allowed
councils to reprofile
debt repayments. This
offered an immediate
benefit of significant
one-off increases to
reserves but these
are not cash backed,
and debt payments
will need to be made
for longer, deferring
costs to later years
which has implications
for future revenue
budgets.
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1. Council funding and financial performance 15
Exhibit 4. 
The bridging actions councils identified within their 2024/25 budgets
as a proportion of net cost of services
Over half of all bridging actions were made up of recurring savings and use of
reserves across Scotland.
0 2 4 6 8
Scotland
Highland
Falkirk
Moray
South Ayrshire
East Lothian
Perth and Kinross
Aberdeenshire
Angus
Eilean Siar
North Ayrshire
Argyll and Bute
East Renfrewshire
Aberdeen City
Scottish Borders
West Dunbartonshire
West Lothian
Dumfries and Galloway
Dundee City
East Ayrshire
Renfrewshire
South Lanarkshire
Inverclyde
North Lanarkshire
Midlothian
City of Edinburgh
Fife
Glasgow City
Percentage
Increase to council tax
Increase to income
Agreed savings recurring
Agreed savings non-recurring
Unidentified savings
Use of reserves
Financial flexibilites
Other
Scotland
Note: In addition to three councils whose 2024/25 annual accounts or 2023/24 data return were
unavailable, Shetland and Orkney are also excluded; both are outliers due to their high use of reserves
to set their budgets, reflecting the councils’ regular use of returns from significant investments
and harbour income. Shetland’s bridging actions made up 39 per cent of their net cost of services
(79 per cent of which related to reserves use). Orkney’s bridging actions made up 15 per cent of their
net cost of services (all of which was use of reserves). Bridging actions were identified as councils set
their 2024/25 budgets and plans, so may have been reduced to reflect previously approved decisions
and can also be subject to in-year changes.
Source: Council data returns for budget bulletins (2024 and 2025) and councils’ annual accounts
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1. Council funding and financial performance 16
Councils did not remain within their agreed revenue
budgets in 2024/25, with more than a third of
councils spending more than was planned
26. Councils set revenue budgets for General Fund services, which
represent most council spending and include major services such as
education and social care. The councils that own and maintain council
housing also set a budget for their Housing Revenue Account (HRA).
Councils generally set balanced HRA revenue budgets, with spending
plans financed largely by rental income.
27. Based on information provided to us via supplementary data returns
(detailed revenue data for 29 councils), councils managed net revenue
budgets of around £16.1 billion in 2024/25, compared to £15.6 billion
in 2023/24.
28. Eleven councils reported an overspend against their total revenue
budgets, and overall, councils reported a revenue budget overspend of
£16.8 million in 2024/25 (0.1 per cent):
• 12 councils overspent against their General Fund revenue budgets
and, collectively, councils reported a £19.4 million (0.1 per cent)
overspend against General Fund revenue budgets totalling
£16.1 billion.
• Councils planned to spend £1.6 billion on housing services,
including transfers to fund capital investment, and reported an
overall overspend of £24.8 million (1.6 per cent). HRA income,
however, was £27.4 million higher than budgeted, resulting in a net
HRA revenue underspend of £2.6 million.
29. Of the 30 councils where there was available data, 15 reported
an overspend on the social care services they deliver on behalf of
Integration Joint Boards (IJBs) totalling around £49 million. This was
due to increased demand for care packages, both home and residential,
alongside an increasing cost for these services. At the same time, several
councils reported service level underspends across a range of services
(Exhibit 5, page 17). We will publish our annual IJB Financial bulletin
2024/25 in February 2026 which will set out in more detail the financial
status of, and outlook for, IJBs.
30. This is the first time an overall overspend for the sector has been
reported in the last six years. Between 2019/20 and 2023/24, councils
reported an overall underspend; however, the size of the underspend had
been decreasing in recent years, and was only 0.2 per cent in 2023/24.
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1. Council funding and financial performance 17
Exhibit 5. 
Councils’ overspends and underspends at a service level and reasons
for them
Almost all councils reported overspends in 2024/25, with less reporting underspends.
Service area Reasons for
Overspends • Overspends were reported across a
wide range of services, particularly
within adult social care services,
education, children and families,
housing and properties and facilities.
• Service area overspends were
mostly attributed to increased
costs of providing services
including inflationary pressures, and
increasing demand for services.
• For education services, staffing
for teacher cover and an increase
in additional support needs were
identified by several councils as a
reason for overspend.
Underspends • Corporate support areas were
the most prevalent areas of
underspend.
• Education also showed many areas
of underspends including workforce
vacancies and specific funding.
• Workforce issues, such as
recruitment freezes, staff vacancies
due to difficulty in recruiting,
particularly in education.
• Delays and slippages in projects
were also a prevalent reason for
underspends this year (which will
have costs in future years).
Source: Council data returns
Councils achieved significant savings, with a third
meeting their full savings target; but some councils
continue to rely on one-off measures to make
savings
31. From a sample of 30 councils, 29 set a savings target in 2024/25,
totalling £376.2 million, and achieved £338.2 million of this
(89.9 per cent). Similar to 2023/24, of those councils that set a savings
target, ten met their full target and 17 achieved 70 per cent or more. Two
councils (Aberdeenshire and Midlothian) achieved less than 70 per cent
of their savings target in 2024/25; both reported a revenue budget
overspend, but only one (Aberdeenshire) would have broken even if its
savings target had been achieved.
32. There is, however, variation in both the scale and ambition of
savings targets across individual councils. Based on the 28 councils
in our sample that set savings targets and provided revenue budget
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1. Council funding and financial performance 18
data, savings achieved were equivalent to 2.2 per cent of total revenue
budgets. Shetland Islands, however, achieved savings equivalent to
4.7 per cent of their revenue budget while Dumfries and Galloway
achieved savings equivalent to only 0.6 per cent of their revenue budget.
33. Twenty-eight of the 29 councils that set saving targets split these
targets into recurring and non-recurring savings. Where we have a
breakdown of how savings were achieved, 86.3 per cent (£270 million)
were achieved on a recurring basis and 13.7 per cent (£42.9 million)
were non-recurring. This compares to 85.5 per cent recurring savings in
2023/24. The split of recurring and non-recurring saving, however, varied
widely among councils, with seven councils relying heavily on one-off
measures to make in-year savings (Exhibit 6, page 19). Using non-
recurring savings to balance council budgets is not sustainable over the
longer term.
34. In our 2023/24 Financial bulletin we recommended that councils
should report on savings made within their management commentaries
more comprehensively, including provision of comparisons to savings
targets agreed during budget-setting, and whether they were recurring or
non-recurring.
35. Councils are still not adequately reporting on savings within their
management commentaries, and only two councils disclosed whether
savings were of a recurring or non-recurring nature. While some councils
report on progress against savings targets, the level of detail provided
can be limited.
Councils spent almost £3.5 billion on capital
investment in 2024/25, with increased spending
supported largely by borrowing
36. The value of councils’ physical assets increased in 2024/25,
with property, plant and equipment increasing by around £3.5 billion
(to £53.7 billion). This increase in value reflects both ongoing investment
and changes to how councils account for leased assets (International
Financial Reporting Standard 16 (IFRS 16): Leases, page 23).
37. Councils remain reliant upon borrowing to finance their investment in
new assets as capital grants reduce, with increased reliance also being
placed upon using internal funds and transfers from revenue budgets.
According to our sample of 30 councils providing information via the
data return, overall capital expenditure was £3.4 billion in 2024/25, a
7.9 per cent annual increase. Of this, £2.2 billion was related to General
Fund projects and £1.2 billion was spent on HRA housing projects.
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1. Council funding and financial performance 19
Exhibit 6. 
Percentage of revenue savings targets achieved in 2024/25, split by
recurring and non-recurring savings
Some councils relied heavily on non-recurring, one-off measures to make in-year
savings in 2024/25.
Percentage of savings target achieved
40 60 80200 100
Scotland (29 councils)
Dundee City
East Ayrshire
Orkney Islands
West Lothian
West Dunbartonshire
Renfrewshire
South Lanarkshire
Perth and Kinross
Falkirk
North Lanarkshire
Glasgow City
Dumfries and Galloway
Eilean Siar
Moray
City of Edinburgh
Angus
East Dunbartonshire
Highland
East Lothian
Aberdeenshire
Midlothian
Argyll and Bute
Shetland Islands
Clackmannanshire
Scottish Borders
North Ayrshire
East Renfrewshire
South Ayrshire
Aberdeen City
Recurring
savings
Non-recurring
savings
Split not
available
Scotland (29 councils)
Note: Inverclyde and Stirling councils did not provide a data return and have been excluded from this
exhibit. Ahead of setting its budget for 2024/25, Fife Council took steps to close its budget gap and
therefore did not set an additional savings target for 2024/25.
Source: Council data returns
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1. Council funding and financial performance 20
38. There is also continued reliance upon funding released from the use
of financial flexibilities relating to accounting for Public Private
Partnerships (PPPs). By extending repayment periods for these contracts,
councils reduced immediate debt costs and eased annual budget
pressures. Recognising prior year overpayments further helped councils
manage contract costs more flexibly in their financial planning. In turn,
this meant councils increased their usable reserves, allowing these to be
used to finance other investment, and reducing the annual impact of PPP
payments on capital budgets (Exhibit 7).
Exhibit 7. 
Capital expenditure split by sources of finance in cash terms, 2023/24
and 2024/25
Borrowing and grants remain the most significant sources of capital finance but
borrowing again increased to offset further reductions in capital grants.
Other contributions and
Public Private Partnership
(PPP)
Internal loans fund
repayments available to
reinvest
Government grants
Capital receipts
Capital Funded from
Current Revenue (CFCR)
An increase in borrowing
2023/24
2024/25
£ million
-0.5 0 0.5 1 1.5 2
Note: Internal loans fund repayments are an annual charge that recognise capital costs in the revenue
budget. Once repaid, they allow borrowed funds to be used elsewhere. Capital receipts are income
councils generate from selling existing assets. Revenue transfers are capital expenditure funded from
service revenue budgets.
Source: Councils’ annual accounts 2023/24 and 2024/25
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1. Council funding and financial performance 21
Despite this increased investment, councils again
underspent on their capital budgets
39. Overall, councils reported a budget underspend of £704.4 million
or 17.2 per cent of the capital budget in 2024/25. This is less than
the underspend reported in 2023/24 (21.3 per cent) and in any of the
previous three years. Underspends were reported for both General Fund
(21.7 per cent) and HRA capital programmes (7.9 per cent).
40. Twenty-eight out of 30 councils underspent against their General
Fund capital budgets in 2024/25 (Eilean Siar reported a balanced
position, while Glasgow City reported a small overspend). Not all councils
build, own and maintain council housing due to having previously
transferred housing stock to housing associations. Of those councils
that do have housing stock, and therefore operate an HRA, 23 out of
25 reported underspends against their HRA capital budgets in 2024/25
(City of Edinburgh and East Lothian were the only councils that reported
overspends due to accelerated programmes of works).
41. The main reasons for these underspends were slippage in projects,
due to capacity and supply chain issues, with capital spend reprofiled into
future years. Time taken for procurement of projects was also a prevalent
reason for underspends. A large number of the capital projects that
slipped this year were within HRA and housing programmes, but school
and large infrastructure projects also showed underspends largely due
to delays.
42. The main challenges councils reported through the data return in
delivering capital programmes over the next five years were:
• affordability – managing the rising costs due to inflation contributing
to high and growing material and labour costs
• the risk of higher interest rates on borrowing for capital projects
• the reliance on funding which can come with limitations and
uncertainty for the future
• a lack of workforce capacity to manage and run several capital
projects.
43. Each year, we ask auditors to consider a specific Best Value theme
as part of their annual audit work and then report nationally on the
findings of this. For 2025/26 audits, which are scheduled to conclude
and report later in 2026, we have asked auditors to consider councils’
approaches to asset management and will report nationally on this in
spring 2027.
44. All councils who provided a data return reported having a multi-year
capital plan in place, with most plans spanning five or more years (25 out
of 30 councils). Most councils include information on their capital plans
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1. Council funding and financial performance 22
within their management commentaries but, as with information on
savings, the level of detail varies. Few provide comprehensive insights
into anticipated expenditure, key projects and future challenges. This
could hinder the ability of decision-makers to make informed choices on
how best to manage finances. It is important that councils are open and
transparent in their reporting to the public and wider stakeholders.
45. Further use of external borrowing, capital underspends and the
impact of IFRS 16 implementation on councils’ financial position
underlines the importance of considering the impact of current
decision-making on longer-term capital investment strategies and plans
(International Financial Reporting Standard 16 (IFRS 16): Leases,
page 23).
An update on the Learning Estate Improvement
Programme (LEIP) and Public Private Partnership
(PPP) contract management
46. Councils continue to progress investment in their school estates, via
participation in the Scottish Government’s Learning Estate Investment
Programme (LEIP). The launch of Phase 3 of the programme confirmed
that 47 schools will be eligible for funding under the programme, with
construction or refurbishment costs being part funded by the Scottish
Government using an outcomes-based 25-year funding model.
47. Fourteen projects have been completed and are now operational,
with a further 16 under construction and 17 at the design stage.
Procurement processes and construction times associated with such
projects means that it is increasingly unlikely that the programme will be
completed by the original planned date of 2027.
48. These delays also mean that there is a lack of certainty around overall
construction costs, which councils must fund, as well as the allocation
of ongoing Scottish Government outcomes-based funding for individual
projects (which are not yet fully finalised as they are based upon project
costs).
49. Alongside management of the LEIP programme, councils continue
to manage the operational aspects of a variety of PPP contacts, including
Public Finance Initiative (PFI) contracts. Earlier PFI contracts are now
nearing their end, with eight set to expire by the end of 2030. Councils
are actively preparing for, or managing, complex exit arrangements.
50. In the 2024/25 Annual Audit Reports we have reviewed (sample of
15), auditors did not raise any concerns around PFI contract expirations
that are in process. However, all reports highlighted the application of
IFRS 16 as a significant audit risk. Additional audit procedures were
undertaken to mitigate this risk, and while some issues were identified,
none were considered material.
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1. Council funding and financial performance 23
International Financial Reporting Standard 16 (IFRS 16): Leases
Councils prepare their accounts under the Code of Practice on Local
Authority Accounting, published annually by CIPFA/LASAAC. The Code is
prepared under International Financial Reporting Standards (IFRS).
Implementation of IFRS 16 became mandatory for councils under the Code
in 2024/25, changing how councils need to account for existing and new
leases. Notably this includes Public Private Partnership (PPP) contracts.
For some leases (finance leases), including PPP contracts, councils already
recognised an asset and corresponding lease liability on their balance sheets.
The main impact of the new requirements therefore is that, for arrangements
previously accounted for as operating leases, a right-of-use asset and a lease
liability must now be recognised on council’s balance sheets.
What IFRS 16 means for councils
In a small number of cases, the application of IFRS 16 resulted in delays
to draft accounts, or drafts accounts being issued where elements of the
changes had yet to be applied.
As IFRS 16 has not been retrospectively applied, from our sample of
15 audited sets of accounts and 14 unaudited sets of accounts, 2024/25
has seen:
• the value of councils’ assets increasing by £3.5 billion, with £0.4 billion of
this due to recognising ‘right of use assets’ under IFRS 16
• an increase in total debt of £2.5 billion (£0.5 billion increase in long-term
liabilities), with £0.8 billion of this overall movement due to recognising
remeasured PPP liabilities under IFRS 16
• this recognition of both assets and liabilities impacting councils’ Capital
Financing Requirements (CFRs), with £0.9 billion of the annual increase of
£2.1 billion attributable to IFRS 16 implementation.
2024/25 audit work on IFRS 16 implementation
In 2024/25, all appointed auditors recognised the implementation of IFRS 16
as a significant risk for councils and carried out additional audit testing and
procedures as part of their work.
Auditors identified a range of issues in how IFRS 16 related changes were
reflected within draft accounts. In all cases, however, corrections were either
made by councils, or any uncorrected misstatements were not material to
the accounts.
No auditors modified their audit opinions due to IFRS 16 implementation.
Overall, the conclusion from 2024/25 audit work reported to date is that
councils appropriately reflected the impact of IFRS 16 in their final accounts.
It has, however, directly impacted debt levels which councils must consider
alongside other key factors within both their capital and borrowing and
treasury management strategies. It is therefore important that all councils
consider the continued affordability of their longer-term capital investment
strategies and plans.
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242. Financial position and outlook
2. Financial position and
outlook
Councils face substantial challenges in maintaining their
financial sustainability over the medium term. A decrease in
usable reserves in 2024/25, most of which are committed for
specific purposes, limits councils’ flexibility in dealing with
emerging pressures and increases overall financial risk.
Councils’ usable reserves have decreased since
2023/24
51. Councils often use reserves as a way of managing their finances,
for example helping to support service transformation to support future
savings. Because reserves are a one-off resource, councils must plan
their use carefully. As budgets come under greater pressure from cost
pressures and increasing demand, it is critical that councils understand
the risks of using reserves to manage short-term budget pressures.
52. In 2024/25, usable reserves decreased from £4.1 billion in 2023/24
to £3.8 billion (Exhibit 8, page 25). This follows a period where
usable reserves have been increasing, from £2.7 billion in 2019/20, that
was attributable largely to increased funding and the use of financial
flexibilities that were introduced in response to the Covid-19 pandemic.
The annual decrease in usable reserves is due to a slight decrease in
capital reserves and a larger (ten per cent) decrease in usable revenue
reserves. The £3.8 billion of usable reserves held by councils at the end
of 2024/25 equates to 22 per cent of their net cost of services.
53. Supplementary information provided to us via data returns shows
that 25 out of 30 councils made planned use of their reserves in 2024/25
(around £325 million) to balance their budgets, meet statutory obligations
and to fund one-off pressures. Sixteen councils also made unplanned use
of reserves (around £78 million). This compares to 12 out of 30 councils
in 2023/24. This unplanned use of reserves was mainly to mitigate
service overspends or to address specific financial pressures.
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2. Financial position and outlook 25
Exhibit 8. 
Councils’ usable reserves, 2019/20, 2023/24 and 2024/25
Usable reserves remain higher than pre-pandemic but have seen a decline in the
last year.
2019/20 2023/24 2024/25
£2.1bn
£3.6bn
Revenue Capital
£3.3bn
2019/20 2023/24 2024/25
£0.6bn £0.6bn £0.5bn
Note: Figures subject to rounding.
Source: Councils’ annual accounts 2019/20 to 2024/25 (audited and unaudited)
Eighty-six per cent of General Fund reserves are
committed for specific purposes, impacting the
level of contingency funding available to manage
emerging pressures
54. The General Fund is the principal usable revenue reserve held by
councils. It can be used for a wide range of purposes, including bridging
budget gaps by supporting both day-to-day service spending and
elements of capital spending. It therefore represents the most readily
available reserve for managing financial pressures.
55. Councils, however, also commit or earmark elements of the General
Fund, identifying where it will be used for a specific purpose. Notably, the
recent trend in General Fund increases since 2019/20 was driven almost
exclusively by committed funds. This means that while, overall, the
General Fund was increasing, uncommitted usable reserves have been
decreasing as a proportion of spending (Exhibit 9, page 26).
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2. Financial position and outlook 26
Exhibit 9. 
Councils’ General Fund balance between 2019/20 and 2024/25, split by
committed and uncommitted
General Fund reserves have declined with 86 per cent committed in 2024/25.
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25
£0.9bn
£1.9bn
£2.3bn £2.4bn £2.4bn £2.2bn£0.4bn
£0.5bn
£0.4bn £0.5bn £0.5bn
£0.4bn General Fund
uncommitted
General Fund
committed
Source: Councils’ annual accounts 2019/20 to 2024/25 (audited and unaudited)
Annual overspends, and a reliance on reserves,
means that a number of councils are now in breach
of their own reserves policies and are taking action
to address this
56. Based on information provided to us via supplementary data returns,
28 out of 30 councils have reserve policies in place, with the majority
(27) setting out a minimum level of uncommitted reserves ranging
between 0.4 and three per cent of budgeted net revenue expenditure.
Some councils base their minimum level on a set monetary value, rather
than a percentage of expenditure; this includes three councils where
the minimum level is less than two per cent of budgeted net revenue
expenditure. Shetland Islands and Eilean Siar are the only councils in the
sample that do not have a formally agreed reserves policy in place.
57. Five councils had uncommitted reserves below their locally agreed
minimum in 2024/25 (Dundee City, City of Edinburgh, Glasgow City,
South Ayrshire and West Dunbartonshire). These councils explained the
reasons for this as in-year overspends, with City of Edinburgh, South
Ayrshire and West Dunbartonshire indicating that they intend to bring
the levels of uncommitted reserves back to target levels for 2025/26.
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2. Financial position and outlook 27
Minimum reserve levels are put in place to not only meet statutory
duties but to ensure financial stability, ie ensuring that there is a buffer
for unplanned spends. If councils breach their minimum reserves levels
this could be a sign that they are reliant on using one-off reserves for
recurring needs.
58. A review of councils’ management commentaries shows that all
councils clearly identify key reserve areas and explain their purpose. Most
councils also specify their minimum reserve level, with those who do not
set a minimum level providing justification for their approach.
Councils must improve the transparency of their
financial reporting
59. As part of good financial management and governance, councils
should report on their finances in a clear and timely manner. At the time
of publishing this report, not all 2023/24 council audits are complete, with
two (Clackmannanshire and East Dunbartonshire) remaining outstanding.
This year, 15 councils met the statutory deadline of 30 September for
preparing audited 2024/25 accounts. At this point, no 2024/25 annual
accounts have been qualified or modified by appointed auditors. Four
councils (Aberdeenshire, Clackmannanshire, East Dunbartonshire
and Stirling), however, failed to meet the 1 July deadline to have their
unaudited accounts available for public inspection.
60. Within the sample of 2024/25 Annual Audit Reports, most councils
were judged to be open and transparent in their financial reporting. The
auditor of one council identified that its financial reports did not support
effective scrutiny, as they were highly technical and not sufficiently
tailored for members without a financial background. A recommendation
was subsequently made that the council should improve reporting
to present key financial information such as budget reports, savings
measures and borrowing in an understandable and consistent way,
including summary information, to better inform decision-making and
allow for scrutiny from elected members. The council agreed to take
action to address this recommendation, with the underlying principle
applicable to all councils.
61. Our review of management commentaries found these were
generally clear and understandable, and consistent with the annual
accounts. However, there was a general lack of clarity about who
was involved in making judgements on financial sustainability. This
is important to demonstrate good governance, transparency and
accountability.
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2. Financial position and outlook 28
Councils are forecasting continuing financial
pressures over the medium term which present risks
to financial sustainability
62. Councils face significant risks to their financial sustainability which
can be influenced by external pressures. These include demographic
changes and rising demand for services (particularly within social care),
ongoing workforce challenges (the subject of our August 2025 report
Delivering for the future: Responding to the workforce challenge),
and current immediate pressures such as homelessness. Additionally,
the implementation of new and existing Scottish Government policies
without sufficient further funding can add to existing challenges.
63. Within the supplementary data returns we issued, and publicly,
councils reported a range of specific financial risks as possible challenges
for their financial sustainability over the next five years. Common issues
highlighted include:
• Future funding: all councils have highlighted single-year
settlements, any potential reductions in government grant funding
and ring-fencing of funds as major challenges. The draft ‘Fiscal
Framework between Scottish Government and Local Government’
has a stated aim of addressing the uncertainty arising from single-
year settlements (paragraph 16).
• Additionally, future reductions in capital grants could mean that
already constrained capital programmes would need to be scaled
back or redesigned, impacting the availability of assets essential for
service delivery. This comes at a time when demand for services
continues to rise.
• Inflationary pressures: councils are reporting existing inflation
pressures as well as economic uncertainty over future inflation and
interest levels as a main challenge. They are also facing pressures
with increased service demand and the associated rising costs of
goods and services, as well as a risk of rising borrowing and capital
financing costs related to increased borrowing being needed to
finance projects due to increasing costs and construction inflation.
• Pay settlements/awards: councils expressed concern about
uncertainty of how future pay awards might be financed. They
reported that a lack of certainty as they negotiate future pay awards
creates a challenge for financial planning. This includes financial
pressures arising from increased employer’s National Insurance
contributions from 2025/26 onwards.
• Council tax: a council tax freeze was implemented in 2024/25,
and while there was no council tax freeze in 2025/26, councils
have highlighted the uncertainty around future council tax rates as
a significant challenge for medium-term financial planning. Councils
also identified that this risk is heightened by their limited capacity to
introduce new local taxes, leaving them reliant on council tax income.
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2. Financial position and outlook 29
• Savings: identifying and achieving additional recurring savings after
implementing substantial savings in recent years was identified as a
challenge by some councils.
• Reserve levels: two councils reported that low reserve levels
and reliance on reserves to fund recurring expenditure, potentially
reflecting difficulties in controlling their base costs.
64. In Local government budgets 2025/26, we reported that Scotland’s
32 councils identified a budget gap of around £647 million at the time of
setting their 2025/26 budgets, with a projected cumulative budget gap
to 2027/28 of £997 million. With financial pressures forecast to continue,
it is important that councils proactively seek to manage these financial
pressures to maintain delivery of services.
Councils have medium-term financial plans in
place, but must continue to prioritise service
transformation to achieve financial sustainability
65. Having robust medium- and long-term financial plans in place is
essential in order for councils to maintain a clear understanding of
financial risks, implement robust risk management processes to monitor
them, and develop indicative forecasts supported by detailed scenario
planning.
66. All 30 councils that provided a data return reported having
medium-term financial plans in place, with the majority spanning
3–5 years (a small number cover a similar period but are due to be
refreshed). Most councils reported that these plans link to their approach
to using reserves over the medium term. Eleven councils also reported
having a long-term financial plan in place spanning over five years. All
councils should consider putting in place longer-term plans to help
mitigate financial sustainability risks.
67. All councils present their medium-term financial plans within their
management commentaries although few councils provide insights into
their longer-term financial outlook. This lack of transparency has the
potential to undermine wider understanding of the challenges councils
are now facing in terms of their financial sustainability. The majority
of councils that did report significant risks to financial sustainability
highlighted uncertainties regarding future funding, pay settlements,
inflation, cost pressures and rising service demand.
68. Given their financial challenges, councils must focus on service
transformation and allocate adequate resources to ensure sustainability.
Within our data return sample, 24 councils identified they hold
committed/earmarked reserves for transformation work. Glasgow
City, Orkney Islands, Shetland Islands, South Lanarkshire and West
Dunbartonshire did not separately identify transformation funds
within their reserves but councils may have other funds to progress
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2. Financial position and outlook 30
transformation. The total value held is around £269 million, which is
around 12 per cent of the total General Fund committed balance and
1.5 per cent of the total net cost of services. The value held varies across
councils, ranging from 0.4 per cent (Aberdeen City) to 9.7 per cent
(Argyll and Bute) as a percentage of their net cost of services.
69. Most councils report on transformational change programmes in
their management commentaries although the level of detail is varied.
Some councils provide detail on specific projects within their programme
plans and the progress against these. As part of their 2024/25 audit
work, we asked auditors to consider the specific Best Value theme
of Transformation as part of their annual audit work, following up on
our October 2024 report Transformation in councils. We will report
nationally on the findings of this work in spring 2026.
Councils’ net debt has increased significantly, with
an annual increase of £2.5 billion, partly driven by
changes in how they account for leases, but also
reflecting ongoing investment
70. In 2024/25, within the 29 sets of council accounts available,
total debt increased to £23 billion (an annual increase of £2.5 billion).
Accounting for investments, this means that councils’ net debt now
stands at £21.9 billion (2023/24: £19.3 billion). The changes associated
with IFRS 16 implementation, with a need to recognise lease liabilities,
has contributed to this increased indebtedness (International Financial
Reporting Standard 16 (IFRS 16): Leases, page 23). Councils again,
however, increased the amount of money they borrowed to invest in
new assets. Long-term external borrowing now sits at £15.5 billion
(an annual increase of £1.2 billion).
71. Councils’ external debt comprises borrowing from a variety of
sources. Temporary borrowing is often undertaken to manage cash flow,
but longer-term borrowing and debt is associated largely with capital
investment and the main sources of this are:
• The Public Works Loan Board (PWLB) – a UK Government agency
that provides long-term borrowing with relatively stable interest
rates, linked to UK Government bonds.
• Market loans – borrowing directly from the banks or other financial
institutions, often undertaken at historical points where they were
cheaper than PWLB loans.
• Lender options/borrower options loans (LOBOs) – historic loans
where the lender can periodically adjust the interest rates (lender
option), providing councils with the choice to accept the new rate or
repay the loan early (borrowing option).
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2. Financial position and outlook 31
72. As well as direct borrowing, councils also recognise a range
of long-term liabilities associated with PPPs and other longer-term
investment contracts which represent committed future repayments,
with 2024/25 figures also now including adjustments related to changes
in how leases, including PPPs, are accounted for.
73. Council debt is reported on their balance sheets at a carrying value
equivalent to the outstanding principal plus any accrued interest. This
means that the amounts reported can vary from the actual amount
borrowed. We asked councils to provide supplementary information
about the value of funds borrowed, as well as the sources of this
funding. Alongside their reported long-term liabilities which are presented
to show the discounted values of future payments (including outstanding
payments under PPP contracts), this has allowed us to present the
sources of debt for 30 councils (Exhibit 10).
Exhibit 10. 
The types of debt held by councils in 2024/25
The vast majority of council debt related to PWLB loans undertaken to invest in
physical assets and infrastructure.
Total debt
£23bn
Public Works Loan Board
£14.6bn (63%)
Other long-term liabilities
£4.3bn (19%)
Temporary borrowing
£1.9bn (8%)
Lender Option Borrower Option
£1.2bn (5%)
Market debt
£0.6bn (3%)
Other source of borrowing
£0.5bn (2%)
Note: This exhibit is based upon 30 council data returns (excluding Inverclyde and Stirling councils).
The gross and net debt figures in paragraph 70 are based on 29 sets of accounts (excluding East
Dunbartonshire, Clackmannanshire and Stirling Councils).
Source: Council data returns
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2. Financial position and outlook 32
Most council debt relates to loans from the PWLB
that will need to be repaid when they end
74. In 2024/25, Scotland’s 32 councils had outstanding PWLB loans
with a principal value of £14.9 billion, an increase of £1.9 billion in the
amount they had borrowed from the previous year. The vast majority
of outstanding PWLB loans, around £12.8 billion, were taken out on
fixed-rate maturity terms. This means that over the length of the loan,
councils pay defined interest payments every six months but, at the
end of the loan, must then repay the principal amount they borrowed
(Exhibit 11, page 33).
75. In practice this means that councils often borrow from the PWLB to
repay earlier loans. Councils are scheduled to repay around £760 million
of PWLB maturity loans in 2025/26, with a further £2.6 billion expected
to be repaid over the next five years. At the same time, the interest
rates on PWLB borrowing have been increasing, reaching the highest
point in a decade. Alongside forecast increases in total borrowing, this
is likely to result in increased interest and debt servicing costs, even if
the current interest rates available are lower than the rates on loans that
are maturing.
Increased borrowing and interest rates mean that
councils are now spending more to service their debt
76. Changing interest rates are having an impact on financing costs
and councils’ financial position more widely. Councils paid £1.2 billion in
interest in 2024/25, an increase from £1 billion the previous year.
77. Councils use Local Government Benchmarking Framework (LGBF)
data to assess their financial sustainability (paragraph 80). Data for
2024/25 shows there has been an increase in the proportion of councils’
revenue budgets allocated to servicing debt in the General Fund, rising
from 5.4 per cent to six per cent in the last three years. For the HRA, the
proportion of the budget servicing debts cost is currently at 21 per cent,
an increase of one percentage point over the last year.
Significant borrowing is still required to finance past
capital investment and to deliver planned capital
investment
78. The capital finance requirement (CFR) is a measure of the cumulative
amount of money a council needs to borrow to finance its capital
expenditure. This means it usefully expresses the maximum potential
amount of borrowing that a council may still have to undertake. In
2024/25 the cumulative CFR stood at £25.9 billion, an increase of
£2.3 billion from 2023/24.
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2. Financial position and outlook 33
Exhibit 11. 
Scotland’s 32 councils had outstanding PWLB loans of £14.9 billion at the
end of 2024/25
Loans of over £12.8 billion, around 86 per cent, were taken out on a maturity basis,
meaning the amount borrowed will need repaid at the end of each loan.
Aberdeen City
Aberdeenshire
Angus
Argyll and Bute
City of Edinburgh
Glasgow City
Clackmannanshire
Comhairle Nan Eilean Siar
Dumfries and Galloway
Dundee City
East Ayrshire
East Dunbartonshire
East Lothian
East Renfrewshire
Falkirk
Fife
Highland
Inverclyde
Midlothian
Moray
North Ayrshire
North Lanarkshire
Orkney Islands
Perth and Kinross
Renfrewshire
Scottish Borders
Shetland Islands
South Ayrshire
South Lanarkshire
Stirling
West Dunbartonshire
West Lothian
0 500 1,000 1,500
£ million
£14.9bn
PWLB
outstanding
principal loans
at the end of
2024/25
Maturity
EIP
Annuity
Note: This exhibit presents the PWLB principal outstanding balance for each council. EIP means
the borrower makes fixed repayments towards the principal each period, while the interest element
changes over the duration of the loan, reducing the overall repayments each period. Annuity means
the borrower makes fixed total repayments on both the principal and interest element of the loan over
the loan period. The level of regular repayment towards the principal element of the loan will increase
over the duration of the loan as the interest element decreases.
Source: Analysis of PWLB annual data as at 31 March 2025
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2. Financial position and outlook 34
79. Around £19.6 billion (76 per cent) of councils’ combined CFR at
the end of 2024/25 related to the General Fund, with the remaining
£6.3 billion attributable to HRAs. This means there was a slight annual
increase in the proportion of the overall CFR relating to the HRA in
comparison to the General Fund of 0.6 percentage points.
Councils are assessing their own financial
sustainability, and benchmarking against others to
inform financial planning
80. Regular monitoring of their own financial sustainability allows councils
to plan more effectively and manage their resources responsibly. To
do this, councils make use of a range of indicators to assess their own
financial sustainability. Based on data returns provided by 30 councils, the
extent to which councils make use of both external and internal indicators
varies, as they have discretion in how they monitor and assess their own
financial sustainability:
• All 32 councils submit data to the Local Government
Benchmarking Framework (LGBF) and 25 councils actively make
use of the LGBF financial sustainability indicators to some extent.
Data for 2024/25 shows that both usable reserves and those
uncommitted reserves available for immediate use have decreased
over the last year.
• Twenty-one councils use the CIPFA level of reserves measure.
This compares the current level of reserves to the council’s net
revenue expenditure.
• Six use the CIPFA reserves sustainability measure. This assesses
how long it will take for a council to use all their reserves if they
continue to allocate as they have.
• Eight use the CIPFA change in reserves sustainability measure.
This monitors the change in a council’s reserves over a
three-year period.
81. Most councils are reporting on their use of financial sustainability
indicators within management commentaries. There is clear evidence
that councils are actively assessing and monitoring their financial
sustainability through practices such as budget monitoring and managing
debt and borrowing.
82. All councils that submitted a data return confirmed that elected
members were provided with a summary of medium- to long-term
financial sustainability during 2024/25, with most presenting this
within budget papers. Some councils also provide updates, varying
between quarterly and annual reporting. Our review of management
commentaries further shows that elected members are sighted on
financial sustainability through budget papers, financial plans, and review
of strategic risk registers, though the level of detail on what is included
can be limited.
The Local
Government
Benchmarking
Framework (LGBF)
includes six financial
sustainability indicators:
• The level of usable
reserves as a
percentage of the
initially approved
annual revenue
budget.
• The uncommitted
General Fund balance
as a proportion of the
initially approved net
revenue budget.
• The share of a
council’s General
Fund net revenue
stream (GRG,
NDR and council
tax income) budget
spent on debt and
financing costs.
• The share of a
council’s Housing
Revenue Account
rental income spent
on debt and financing
costs.
• Revenue outturn
compared to final
budgeted revenue
budget (General
Fund and HRA,
where applicable).
• Approved use of
reserves to address
budget gaps as a
percentage of net
expenditure (new for
December 2025).
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2. Financial position and outlook 35
83. All councils provided details to us via supplementary returns about
who is responsible for assessing financial sustainability. The chief finance
officer (or equivalent) is responsible for monitoring the council’s financial
position and regularly reporting back to elected members, strategic
leadership teams, and finance officers. But this is not always clearly
reported within management commentaries (paragraph 61).
There are increasing signs that sustained pressures
have impacted the financial position of councils,
and there are risks to financial sustainability in the
medium term
84. Councils’ net revenue streams have generally increased in line
with their net costs of services. Councils, however, have been making
significant savings to reduce costs, and funding changes largely reflect
increased baselining of funding into the GRG. Our analysis of 2024/25
accounts and related information suggests that, over a range of
measures, the financial position of Scotland’s councils is worsening:
• General funding has been increasing but more of it is directed,
reducing the flexibility councils need to address cost pressures
(paragraphs 11–12).
• Councils have not generated other income at a rate that has kept
pace with inflation (paragraphs 18–21).
• Identifying recurring savings can become progressively more
difficult over time and, while councils have largely been successful
in delivering savings, many are reliant on non-recurring savings
which do not address underlying issues (paragraph 31).
• Usable reserves are now decreasing and, notably, uncommitted
General Fund reserves are decreasing (Exhibit 8, page 25 and
Exhibit 9, page 26).
85. At the same time, capital projects are becoming increasingly
expensive. Councils have been borrowing more, and the financing of
ongoing investment is increasingly expensive. External debt is increasing
(paragraph 70) and a number of councils are spending more servicing
their debt, across both their General Fund and services and HRA
(paragraph 77). Projected borrowing as measured by the CFR is also
increasing (paragraph 79).
86. Against this backdrop, councils again forecast significant budget gaps
when setting their 2025/26 budgets, with further savings required to
address them, alongside the continued planned use of reserves, despite
ongoing transformation programmes. Without sustained and recurring
financial pressures being addressed, across a range of indicators there
are signs that councils will become financially unsustainable over the
medium term, despite ongoing transformation and identification of
efficiencies.
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2. Financial position and outlook 36
Upcoming work
87. How councils plan to use their reserves, make savings and
transform their services needs to become more transparent as financial
sustainability issues are addressed. In our next budget briefing, Local
government budgets 2026/27, we will examine the decisions that
Scotland’s councils take as they set their budgets (including setting
council tax), the finalised funding settlement from the Scottish
Government, decisions and the steps they intend to take to fund and
transform their services.
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37Appendix
Appendix
Progress against the recommendations in
Local government in Scotland: Financial bulletin 2023/24
In 2025, councils should: Progress/status
Report on the savings made within
their management commentaries more
comprehensively, including provision of
comparisons to savings targets agreed
during budget-setting, and whether they
were recurring or non-recurring.
Limited progress
• Councils are still not adequately reporting on
the delivery of savings in their management
commentaries, including whether savings are
recurring or non-recurring (paragraph 35).
• The report includes an updated
recommendation on how councils must
adequately report information on the
delivery of savings within their management
commentaries.
Ensure that the impact of capital
underspends, future borrowing projections
and of using financial flexibilities on their
indebtedness are reported clearly alongside
the impact of these of future revenue
budgets.
Limited progress
• Our review of council management
commentaries found limited references to
the impact of current financial decisions, such
as capital underspends, new borrowing and
utilising financial flexibilities, will have on future
revenue budgets.
• This report includes a recommendation on
how councils should clearly explain within
their management commentaries how future
revenue budgets will be impacted by current
financial decisions.
Ensure reserve policies indicate explicitly
and clearly the impact of financial flexibilities
on reserves held; the nature, level of and
intended timing of the deployment of
committed usable reserves held; and the
level of uncommitted and contingency
funding held within General Funds.
In progress
• Most councils have a reserve policy which
sets out the minimum level of reserves
to be held, including those uncommitted.
Five councils breached their minimum
level for uncommitted reserves in 2024/25
(paragraphs 56–57).
Cont.
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Appendix 38
In 2025, councils should: Progress/status
Prioritise service transformation, considering
the impact of current service delivery models
on longer-term financial sustainability,
including the medium-term impact on
reserve levels.
In progress
• Most councils use their management
commentaries to report on transformation
activities, but the level of details varies. Not
all councils hold committed reserves for
transformation activities (paragraphs 68–69).
• Councils need to continue to prioritise
transformation activities to address financial
challenges.
• The report includes an updated
recommendation for councils to clearly report
on the level of committed reserves held for on
transformation activities.
Ensure that financial sustainability becomes
a central focus of financial monitoring and
reporting, making greater use of financial
sustainability indicators within reports to
elected members and within their regular
public reporting and financial strategies
and plans.
In progress
• Most councils regularly report financial
sustainability indicators to elected members.
There is discretion on how councils do
this with not all councils fully using the
LGBF financial sustainability indicators
or CIPFA’s level of reserves indicators
(paragraphs 80–83).
• An updated recommendation on the use of
financial indicators in monitoring and reporting
is included in this report.
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Local government in Scotland
Financial bulletin
2024/25
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500
www.audit.scot
ISBN 978 1 915839 99 2
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Page 89

Audit Committee
Monday 23 February 2026
Item No 5.3   
Treasury Management and Investment Strategy 2026/27 & Prudential
Indicators 
Report by David Gladwin, Chief Finance Officer and Section 95 Officer 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to comment on this report before it is
presented to Council.  In particular, Audit Committee should note the
following recommendations which are proposed to be put to Council on
24 February 2026:- 
a) Approve the restriction of the Authorised Limit to the value of
the Capital Financing Requirement at 31 March 2027
(£693.930 million); 
b) Note that there are no material changes proposed to the
Treasury Management and Investment Strategy (TMIS) for
2026/27 from the strategy currently in place, other than to
update the Prudential Indicators (Section 5 and Appendix 2),
to reflect the revised capital plans; 
c) Note the continued use of the Asset Life method for the
repayment of all loans fund advances as outlined in Section 6;
and 
d) Accordingly approve the Treasury Management and
Investment Strategy for 2026/27. 
2 Purpose of Report/Executive Summary 
In accordance with the Treasury Management Code of Practice, the
annual Treasury Management & Investment Strategy (TMIS) &
Prudential Indicators report is required to be adequately scrutinised
before being recommended to the Council.  For Midlothian, this role is
undertaken by the Audit Committee, with this report being presented to
Audit Committee on 23 February 2026 prior to consideration by Council
on 24 February 2026. 
The purpose of the report to Council will be to provide an update on the
implementation of the Council’s TMIS 2025/26, and to make
recommendations to facilitate consideration of the 2026/27 Strategy,
specifically the TMIS for 2026/27, the Prudential and Treasury
indicators contained therein, and the approach to the statutory
repayment of loans fund advances. 
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Any revisions arising from Audit Committee consideration of the report
on 23 February 2026 will be verbally updated to Council before
discussing the report on 24 February 2026. 
Date: 4 February 2026
Report Contact:
Gary Thomson, Senior Finance Business Partner
gary.thomson@midlothian.gov.uk 
3. Update on implementation of TMIS for 2025/26 
3.1 Borrowing 
The Council’s borrowing position as set out in the 2025/26 Treasury
Management Mid-Year Review Report was £379.445 million at 31
March 2025, and six months later was £418.575 million on 30
September 2025. 
The principal source of borrowing is the UK Debt Management
Office’s Public Works Loans Board (PWLB) and fixed rate loans are
taken at a time and tenure which takes cognisance of the PWLB rates
(derived from the UK Gilts market) and the management of maturity
risk in the long term across the Council’s loan portfolio. 
The Council’s loan portfolio, as at 30 January 2026, is shown in table
1 below:- 
Table 1: Current Loan Portfolio as at 30 January 2026 
Loan Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
PWLB Annuity 332 8.92%
PWLB Maturity 340,283 3.12%
PWLB EIP 67,542 4.24%
LOBO 15,000 4.63%
Market Loans 19,866 3.04%
Total Loans 443,024 3.34% 
3.2 Deposits 
The Council’s position for funds on deposit fluctuates on a daily basis,
with the 2025/26 Treasury Management Mid-Year Review Report
setting out the position at 31 March 2025 of £26.484 million and six
months later on 30 September 2025, at £39.910 million. 
The position at 30 January 2026, as set out in Table 2 below, totals
£30.372 million. 
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Table 2: Current Deposits as at 30 January 2026 
Deposit Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
Bank Call Accounts 683 3.51%
Money Market Funds 19,689 3.88%
Bank Fixed Term Deposits 10,000 4.18%
Total Deposits 30,372 3.97% 
The Council’s current deposit portfolio is broadly reflective of the wider
UK Local Authority position, as noted in the Treasury Management &
Annual Investment Strategy Statement – 2026/27 Detailed in
Appendix 3, Section 4.4. 
4. Treasury Management & Investment Strategy 2026/27 
4.1 Main Objectives of TMIS 2026/27 
The objectives of the proposed TMIS are:- 
• To secure long-term borrowing to fund capital investment,
through locking in to long-term interest rates and de-risking
the Council’s Capital Financing Requirement (CFR); 
• To ensure short-term liquidity to manage the Council’s day-to-
day cashflow.  This is achieved through the utilisation of
instant access Money Market Fund and Bank Accounts, with
the amount held in these reflecting the Council’s level of
working capital and fluctuating throughout the year due to a
number of factors; 
• To partly (but not fully) cash-back the Council’s usable
reserves (see Section 4.4 – Investment Strategy), to allow the
Council to defer new borrowing until interest rates are
expected to drop. 
In addition, approval is sought to restriction the Authorised Limit to the
value of the Capital Financing Requirement at 31 March 2027
(£693.930 million) (see Section 5 – Prudential Indicators), 
There are no changes recommended to the Permitted Investments. 
More detail on the borrowing and investment strategy for 2026/27 is
provided in Sections 4.2, 4.3 and 4.4 below. 
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4.2 Borrowing Requirement 2025/26 to 2029/30 
The Council’s capital plans contain projections of capital expenditure
and income over the forthcoming financial years.  Any expenditure not
financed directly by income, requires funding through borrowing. 
The projected borrowing requirement arising from the Council’s
Capital Plans and the maturing long-term loans that require to be
refinanced, over the period 2025/26 to 2029/30 is shown in table 3
overleaf:- 
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Page 93

Table 3: Total Borrowing Requirement over the period 2025/26 to 2029/30 
2025/26
£000’s
2026/27
£000’s
2027/28
£000’s
2028/29
£000’s
2029/30
£000’s
Total
£000’s
Capital Expenditure      
General Services 59,004 107,038 132,248 101,566 34,436 434,292
HRA 59,999 88,419 69,783 47,355 48,724 314,280
Total Capital Expenditure 119,003 195,457 202,031 148,921 83,160 748,572
Total Available Financing -33,374 -38,710 -32,453 -32,156 -20,054 -156,747
Principal Debt Repayments -10,884 -12,018 -14,472 -16,734 -18,567 -72,675
Capital Expenditure less
available Financing 
74,745 144,729 155,106 100,031 44,539 519,150
Maturing Long-term Loans 16,424 19,425 19,690 39,697 29,697 124,933
Total Borrowing
Requirement
91,169 164,153 174,796 139,728 74,236 644,083
Borrowing secured 2025/26 -80,000 0 0 0 0 -80,000
Total Remaining Borrowing
Requirement
11,169 164,153 174,796 139,728 74,236 564,083 
4.3 Borrowing Strategy for remainder of 2025/26 and 2026/27 
Strategy for remainder of 2025/26 
The approved Treasury Management Strategy for borrowing for the
remainder of 2025/26 is to fund the in-year Capital Financing
Requirements from PWLB for a relatively shorter-term duration (3-5
year debt tenors), to navigate past the current interest rate hump, with
gilt yields expected to gradually ease throughout the course of the
next 12-36 months.  This strategy remains prudent given current &
forecast interest rates. 
The Council’s external loan debt at 31 March 2026 is projected to be
£458.024 million.  Based on the Council’s historic and current
approved Capital Plans, the Underlying Borrowing Requirement
(UBR) – which is the Council’s underlying need to borrow for capital
purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2026 is expected to equate to £549.201
million (see Appendix 2, Table 2.3). 
This means that the Council is expected to be £91.177 million (17%)
under-borrowed at the end of the 2025/26 financial year i.e. the
Council has funded the majority (83%) of its underlying borrowing
requirement as at 31 March 2026.  In the current economic climate,
this is a prudent approach which balances (a) de-risking the longer
term borrowing requirement at current longer term borrowing rates;
against (b) the current year and forthcoming financial year budget
projections; and is in line with the majority of other Scottish Local
Authorities. 
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Strategy for 2026/27 
Looking forward, as can been noted from Table 3 above, the Council
has a significant borrowing requirement across the forthcoming four
financial years (2026/27 to 2029/30). 
The Underlying Borrowing Requirement, driven by the Council’s
approved capital plans, is projected to rise to £993.606 million by 31
March 2030 (see Appendix 2, Section 2.3) – more than double the
current external debt portfolio value of £443.024 million.  The profile of
this, and the projected external loan portfolio to fund the Underlying
Borrowing Requirement over the period 2025/26 to 2029/30, is shown
in graphical format below. 
Figure 1: Projected Loan Portfolio & Underlying Borrowing
Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the
curve at the time of writing sitting at the shortest tenors (1-3 years @
c. 4.50%; certainty rate) with rates trending upwards towards the 25-
30 year tenor (high point of 6.03%; certainty rate) before easing back
slightly to sit at c. 5.79% (certainty rate) in the 50 year duration. 
Current PWLB rates have generally increased by c. 20-30bps across
the medium-longer end of the interest rate curve from levels reported
at the time of the 2025/26 TMIS to Council in February 2025, and as
noted in the TM Mid-Year Review Report to Council in December
2025, are expected to remain elevated for longer, particularly at the
medium-longer end of the curve. 
The forward-looking Interest Rate Forecast from the Council’s
Treasury Advisers, MUFG Corporate Markets, is shown in Table 4
below, with further commentary on this is provided in Appendix 3
Section 3.3 and Appendix 5.1. 
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Table 4: MUFG Interest Rate Forecasts 
As can be noted in Table 4 above, the yield curve is expected to
remain bell shaped over the short-medium term, with a gradual shift
downwards of the entire curve by c. 30-40bps over the next 12
months, a further 10-20bps over the subsequent 12 months and a
further 10bps in the medium/longer end over the following 12 months
of the forecast period (so 50-60bps total). 
This is forecast to bring longer-term borrowing rates down from
between 5.79%-6.03%, to between:- 
• 5.60%-5.80% by March 2026;
• 5.30%-5.50% by March 2027; and
• 5.10%-5.30% by March 2028. 
Borrowing Strategy 
The funding of the Council’s in-year and forward CFR is typically for
infrastructure with long asset lives (50-60 years), and the tenor of
PWLB and market loans are typically drawn with this in mind. 
Given the Council’s borrowing requirement across 2025/26 to 2029/30
as outlined in Table 3, and the Interest Rate Forecasts as outlined in
Table 4, consideration for any new borrowing, to fund the Council’s
CFR, will seek to balance:- 
a) the security/certainty of current relatively high longer-term
borrowing rates of upwards of 5.60% in the 30-50 year duration
(which are forecast to drop by 30bps within one year and a total
of 50bps within 24 months) and the potential additional
budgetary pressure that this brings in both the short/medium
and longer term; with 
b) the option to borrow initially for a shorter-term duration from
PWLB or other markets, for 3 to 5 years (at say c. 3.80-4.20%
at the HRA rate), to allow the Council to fund the immediate in-
year borrowing requirement.  Based on current interest rate
forecasts (see Appendix 3 Section 3.3), this would then allow
the Council the option to refinance this borrowing at initial 3-5
year maturity with less expensive, longer term borrowing, e.g. a
45 to 47 year tenor in, say, 36 months at a forecast rate of c.
4.60-4.80% (HRA Rate). 
Bank Rate 3.75% 3.50% 3.50% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25%
3 month average earnings 3.80% 3.50% 3.50% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30%
6 month average earnings 3.80% 3.50% 3.50% 3.40% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30%
12 month average earnings 3.90% 3.60% 3.60% 3.50% 3.40% 3.50% 3.50% 3.50% 3.50% 3.50% 3.60% 3.60% 3.60%
5 year PWLB 4.60% 4.50% 4.30% 4.20% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10%
10 year PWLB 5.20% 5.00% 4.90% 4.80% 4.80% 4.70% 4.70% 4.70% 4.70% 4.60% 4.60% 4.60% 4.70%
25 year PWLB 5.80% 5.70% 5.60% 5.50% 5.50% 5.40% 5.30% 5.30% 5.30% 5.20% 5.20% 5.20% 5.20%
50 year PWLB 5.60% 5.50% 5.40% 5.30% 5.30% 5.20% 5.10% 5.10% 5.10% 5.00% 5.10% 5.00% 5.00%
MUFG Corporate Markets Interest Rate View
Mar-28 Jun-28 Sep-28 Dec-28 Mar-29Mar-26 Jun-26 Sep-26 Dec-26 Dec-27Sep-27Jun-27Mar-27
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Any further long-term borrowing that is undertaken to finance the
current & future year capital plans is expected to be sourced by
drawing new PWLB loans at the Certainty Rate (which has been
available to the Council since 2012 and is priced at Gilts+80bps),
and/or the HRA rate.  The HRA rate is available to all Councils to fund
HRA capital expenditure, at a rate that is priced at Gilts+40bps, with
an extension of the availability of this rate beyond 31 March 2026 (and
so into financial year 2026/27) announced by the UK Government’s
Ministry of Housing, Communities & Local Government (MHCLG) on
28 January 20261.  Other market-led longer-term borrowing
opportunities will be benchmarked against the prevailing PWLB rates
to assess whether they offer value to the Council. 
Council officers, in conjunction with MUFG, will continue to monitor
daily long-term borrowing rates in order to take advantage of any dips
in the market or to de-risk any change in the medium-longer term
forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a
‘forward dealing’ basis, and officers will continue to explore the
viability of these loans as part of securing the long term borrowing
required to meet the Council’s Underlying Borrowing Requirement. 
Review of Capital Plans & Impact on Borrowing Strategy 
Both the General Services and HRA capital programmes are being
kept under regular review due to the effects of inflationary pressures,
shortages of materials and labour, and the ratios of financing costs to
the net revenue streams.  The Council’s borrowing strategy will,
therefore, also be regularly reviewed and then revised, if necessary,
to achieve optimum value and risk exposure in the medium-long-term. 
Debt Rescheduling 
As noted in the Mid-Year Review Report, the Council elected to
reschedule (prematurely repay) PWLB debt as follows:- 
• £12.700 million PWLB Maturity loan, original drawn date of 2
August 2007 and existing maturity date of 15 May 2053, at a
fixed interest rate of 4.55% 
Any further debt rescheduling will be considered when the difference
between the refinancing rate and the redemption rate is most
advantageous and the situation will be continually monitored in order
to take advantage of any perceived anomalies in the yield curve.  The
reasons for any rescheduling taking place would include: 
- the generation of cash savings at minimum risk;
- to reduce the average interest rate;
- to amend the maturity profile and/or the balance of volatility of
the debt portfolio. 
1 Thousands more families to get warm, secure social homes - GOV.UK
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Council officers will explore debt rescheduling opportunities with
MUFG Treasury Solutions; with only prudent and affordable debt
rescheduling that considers both the short and medium-longer term
impact being considered. 
4.4 Investment Strategy for remainder of 2025/26 and 2026/27 
No changes are proposed to the Investment Strategy from that
approved by Council in the 2025/26 TMIS. 
As noted in Section 4.1, the Council is partly (but not fully) cash
backing its usable reserves, instead using these balances to allow the
deferral of borrowing at the current high interest rates payable, to
allow the Council to most effectively navigate past the current interest
rate plateau of the next 36 months, when rates on longer term
borrowing are expected to drop by 50-60bps. 
All deposits will be placed with high creditworthy counterparties in
accordance with the approved creditworthiness policy as outlined in
Appendix 1, with a tenor reflective of the expected drawdown of
useable reserve forecasts, and at a yield commensurate with this. 
Environmental, Social & Governance factors will also be considered;
however as noted in previous Treasury Management Strategy reports
the Governance element (and associated security of deposit) remains
the primary criteria for Midlothian.  For further detail see Appendix 3,
Section 4. 
The list of Permitted Investments in Appendix 1 remains unchanged
from that approved by Council in the 2025/26 TMIS. 
As required by the CIPFA Treasury Management Code, Local
authorities “must not borrow to invest for the primary purpose of
financial return.”  Midlothian Council does not and has not borrowed to
invest for the primary purpose of financial return. 
5 Prudential Indicators – Midlothian Council 
The Prudential Code for Capital Finance in Local Authorities requires
that Councils can demonstrate that their Capital Plans are affordable,
prudent and sustainable, taking into account the financial provisions
made in current and future revenue budgets; and that Treasury
Management decisions are taken in accordance with good practice. 
The Prudential Indicators that Councils need to consider relate to both
actual, historic outcomes, and future estimated outcomes (covering
the same period as the Council’s Capital Plans), as follows:- 
• Actual outcomes for 2024/25;
• Revised estimates of the 2025/26 indicators; and
• Estimates of indicators for 2026/27 to 2029/30. 
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The Prudential Indicators required by the Code are listed individually
in Appendix 2. 
The key Prudential Indicators relating to the Underlying Borrowing
Requirement, the expected Gross External Debt, and the proposed
Authorised Limit, are shown in graphical format below. 
Figure 4: Prudential Indicators for Borrowing 
The Capital Financing Requirement (CFR) denotes the Council’s
underlying need to borrow for capital purposes.  The CFR includes
borrowing arising as a result of the Council’s Capital Plans, plus the
long-term liability arising from the Council’s PPP/DBFM contracts. 
The Underlying Borrowing Requirement as shown in Figure 4
above strips out the latter of these (long-term liability arising from the
Council’s PPP/DBFM contracts) from the CFR. 
The Authorised Limit for Borrowing represents the limit beyond
which borrowing is prohibited, and needs to be set and revised by
Members.  It is the expected maximum borrowing need with some
headroom for unexpected movements. 
The Authorised Limit for Borrowing for the 2026/27 financial year has
been calculated to equate to the maximum value of the Underlying
Borrowing Requirement in 2026/27.  This equates to £693.930 million
as outlined in Table 6 below. 
Table 6: Authorised Limit for Borrowing: Calculation 
Authorised Limit for Borrowing Amount
£000’s
CFR – General Services (31 March 2027) 296,175
CFR – HRA (31 March 2027) 397,755
Proposed Authorised Limit for Borrowing 693,930
Council is therefore asked to approve an authorised limit for borrowing
of £693.930 million (see Appendix 2, Section 4.2).  
458,024
611,479
775,282
876,652 922,002
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
£1,000,000
2025/26 2026/27 2027/28 2028/29 2029/30
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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6 Statutory repayment of loans fund advances 
Under the Local Government Finance Circular 7/2016, Council is
required to set out its policy for the statutory repayment of loans fund
advances prior to the start of each financial year. The repayment of
loans fund advances ensures that the Council makes a prudent
provision each year to pay off an element of the accumulated loans
fund advances made in previous financial years. 
6.1 New Assets 
In accordance with Finance Circular 7/2016, for all advances made in
relation to the provision of a new asset, the policy will be to defer the
commencement of the first principal repayment of the loans fund
advance until the financial year following the one in which the asset is
first available for use. 
6.2 Prudent Repayment of Loans Fund Advances 
Finance Circular 7/2016 provides a variety of options to Councils for
the profiling of the repayment of each loans fund advance, so long as
the principle of prudence is maintained.  For the 2026/27 financial year,
there are 3 options available: (a) Asset Life method; (b) Depreciation
method; and (c) Funding/income profile method. 
In line with the policy adopted in 2025/26, the Asset Life method shall
be used for those assets in Table 7. 
Table 7: Asset Classes adopting the “Asset Life” method
Infrastructure
Current
Loans
Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20 
The annual repayments under the “Asset Life” method for those asset
classes as noted above will be calculated using the asset lives and will
use the annuity method, in line with previous years.  The annuity
interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund
rate, which for 2026/27 is currently estimated to be 2.97%. 
For all other asset classes, the policy will also be to profile the annual
repayments under the “Asset Life” method, with the profile also
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calculated using the annuity method.  The annuity interest rate that will
be used to calculate loans fund principal repayments under the “Asset
Life” method will be the in-year loans fund rate, which for 2026/27 is
currently estimated to be 2.97%. 
Whilst neither the Depreciation nor the Funding/income profile methods
are currently proposed, Council officers will continue to monitor whether
it is appropriate to use this for future capital projects. 
7. Report Implications 
7.1 Resource 
There are no direct resource implications arising from this report. 
7.2 Digital 
None 
7.3 Risk 
The strategies outlined in this report are designed to maintain the
effectiveness of the overall risk management arrangements for
Treasury activity.  Providing the limits outlined in the strategies are
observed they will support the controls already in place in the
Treasury Management Practices within which the treasury function
operates. 
The Prudential Indicators contained in Appendix 2 maintain the
effectiveness of the overall risk management of Capital Investment
and Treasury Management. 
7.4 Ensuring Equalities 
There are no equality issues arising from this report. 
7.5 Additional Report Implications 
See Appendix A. 
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Appendix A: Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Not applicable. 
A.2 Key Drivers for Change 
A.3 Key Delivery Streams 
Themes addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
The report does not directly impact on Delivering Best Value. 
A.5 Involving Communities and Other Stakeholders 
Although no external consultation has taken place, cognisance has
been taken of professional advice obtained from MUFG Asset
Services, the Council’s appointed Treasury Consultants. 
A.6 Impact on Performance and Outcomes 
The strategies to be adopted are an integral part of the corporate aim
to achieve Best Value as they seek to minimise the cost of borrowing
by exercising prudent debt management and investment. This in turn
helps to ensure that the Council’s capital expenditure is sustainable in
revenue terms. 
A.7 Adopting a Preventative Approach 
Not applicable. 
A.8 Supporting Sustainable Development 
Not applicable. 
Background Papers:-
Appendix 1:- Permitted Investments
Appendix 2:- Prudential Indicators
Appendix 3:- Treasury Management & Annual Investment Strategy
Statement – 2026/27 Detailed
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Permitted Investments Appendix 1 
The Council uses the MUFG creditworthiness service for specific categories of permitted
investments.  This utilises credit ratings from the three main credit rating agencies – Fitch,
Moody’s and Standard & Poors, along with credit watches, outlooks, CDS spreads and country
sovereign ratings in a weighted scoring system with an end product of a series of colour coded
bands which indicate the relative creditworthiness of specific categories of counterparties for
investment. 
These colour codes are used by the Council to determine the maximum suggested duration for
investment with that counterparty.  These are as follows:- 
MUFG
Colour Code
Maximum Suggested
Duration for Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent, Money
Market Funds (MMF's), and collateralised deposits where the collateral is UK Government
Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25; Light Pink for Ultra
Short Dated Bond Funds with a credit score of 1.5
*** Only applies to nationalised or semi-nationalised UK banks 
Note that the maximum suggested durations listed above have been extended by 1 year (when
compared to the suggested maximum durations provided by MUFG) for the Yellow, Dark Pink,
Light Pink categories (and so to 6 years); the Purple category by 6 months to 2.5 years; the Blue
and Orange categories by 3 months to 1.25 years; the Red category by a month to 7 months, and
the Green category by 20 days to 120 days.  This is to allow flexibility around these durations on
the margins e.g. the placement of a 13 month fixed term deposit for a counterparty rated Orange
or Blue.  A thorough appraisal of the additional risk involved in extending the duration of any deposit
(marginally) beyond the maximum suggested by MUFG, against any enhanced value to the
portfolio, will be undertaken prior to the placement of any deposit. 
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1.1  Deposits 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Debt Management Agency
Deposit Facility -- Term No 100% 6 months
Term deposits – local authorities -- Term No 100% 5 years
Call accounts – banks and
building societies Green Instant No 100% 1 day
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.2 Deposits with counterparties currently in receipt of government support / ownership 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day
UK nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 1.25 years
UK nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 1.25 years
Non-UK(high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
If forward deposits are made, the forward period plus the deal period equate to the maximum maturity
period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies (OEICs) 
Investment Category
Minimum
Credit
Criteria 
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Government Liquidity Funds AAA Instant No 100% 1 day
Money Market Funds CNAV AAA Instant No 100% 1 day
Money Market Funds LVNAV AAA Instant No 100% 1 day
Money Market Funds VNAV AAA Instant No 100% 1 day
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week
Bond Funds AAA T+2 or
longer Yes 50% 2 days
Gilt Funds AAA T+2 or
longer Yes 50% 2 days 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 50 years
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 25 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
Midlothian Energy Limited n/a Term No £10.2m n/a 
Treasury Risks and Mitigating Controls for each type of investment are as outlined in the Treasury
Management & Annual Investment Strategy Statement – 2023/24 Detailed – Appendix 5.3.  The Council’s
Treasury Management Practices have also been updated in line with the new CIPFA Prudential and
Treasury Management Codes which were approved by Audit Committee on 6 December 2022.  
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Prudential Indicators Appendix 2 
1. Prudential Indicators for Affordability 
These indicators provide an indication of the impact of the capital investment plans on the
Council’s overall finances. 
1.1 Estimates of Ratio of Financing Costs to Net Revenue Stream 
This indicator identifies the trend in the cost of capital (borrowing and other long term obligation
costs net of investment income) against the net revenue stream. 
The figures above are based on the current General Services and HRA Capital Plans. 
1.2 HRA Ratios 
The following indicator identifies the ratio of overall debt on the HRA account compared to annual
house rent revenue. 
The following indicator identifies the ratio of overall debt on the HRA account per HRA dwelling. 
1.3 Net Income from Service & Commercial Investments as a proportion of Net Revenue Stream 
An indicator, which is a requirement of the new Prudential Code, identifies the ratio of net income
from service and commercial investments as a proportion of the net General Services revenue
stream. 
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
General Services 1.41% 1.81% 2.66% 3.89% 5.20% 6.01%
HRA 42.69% 47.04% 51.43% 57.16% 58.14% 58.28%
Ratio of Financing Costs to Net Revenue Stream
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 283,242£  325,235£  397,755£  442,630£  466,732£  496,802£ 
HRA Revenues £000's 36,382      37,917      41,300      44,818      48,384      51,321     
Ratio of HRA Debt to Revenues
% 779% 858% 963% 988% 965% 968%
HRA Debt as a % of Gross Revenue
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 283,242£  325,235£  397,755£  442,630£  466,732£  496,802£ 
Number of HRA dwellings 7,448        7,654        7,951        8,165        8,333        8,432       
Debt per dwelling £ 38,029£    42,492£    50,026£    54,211£    56,010£    58,919£   
HRA Debt per Dwelling
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2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Income from Service Investments          34           34           34           34           34           34
Net Revenue Stream 294,134  317,181  327,812  334,347  341,038  347,891
% 0.01% 0.01% 0.01% 0.01% 0.01% 0.01%
Net Income from Service Investments as a proportion of Net Revenue Stream
%
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2. Prudential Indicators for Capital Expenditure 
The Council’s capital expenditure plans are the key driver of treasury management activity.  The
output of the capital expenditure plans is reflected in the prudential indicators, which are designed
to assist members’ overview and confirm capital expenditure plans. 
2.1 Estimated Capital Expenditure 
This indicator shows the gross capital spend included in the relevant capital plans. 
2.2 Financing of Capital Expenditure 
This indicator shows how the Capital Expenditure forecasts are being financed by capital or
revenue resources.  Any shortfall of resources results in a funding borrowing need. 
2.3 Estimated Capital Financing Requirement 
This indicator measures the Council’s maximum underlying need to borrow for capital purposes
and other long term liabilities over the next three years. 
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 17,218£    21,977£    71,726£    106,520£  84,850£    18,590£ 
Asset Management 13,334£    18,593£    19,262£    17,066£    14,250£    14,811£ 
Transport, Energy & Infrastructure 2,346£      5,821£      8,654£      2,233£      428£         428£      
Regeneration & Development 15,078£    13,343£    8,604£      8,963£      5,232£      3,050£   
Other 1,058£      465£         297£         180£         180£         180£      
Provision for return of contingencies -£              (1,194)£    (1,505)£    (2,714)£    (3,374)£    (2,624)£  
Total General Services 49,034£    59,004£    107,038£  132,248£  101,566£  34,436£ 
Total HRA 53,174£    59,999£    88,419£    69,783£    47,355£    48,724£ 
Combined Total 102,208£  119,003£  195,457£  202,031£  148,921£  83,160£ 
Capital Expenditure
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 49,034£     59,004£    107,038£  132,248£  101,566£  34,436£ 
HRA 53,174£     59,999£    88,419£    69,783£    47,355£    48,724£ 
Total 102,208£   119,003£  195,457£  202,031£  148,921£  83,160£ 
Financed by:
Capital receipts 175£          -£             -£             -£             -£             -£           
Capital grants 25,191£     27,390£    24,588£    25,307£    19,833£    14,869£ 
Capital reserves -£               -£             -£             -£             -£             -£           
Developer/Other Contributions 3,218£       5,984£      14,122£    7,146£      12,323£    5,185£   
Net financing need for the year 73,624£     85,629£    156,747£  169,578£  116,765£  63,106£ 
Capital Expenditure and Available Financing
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3. Prudential Indicators for Prudence 
3.1 Net Borrowing Requirement 
This indicator shows the amount of external borrowing required to finance the current debt
outstanding on capital projects. 
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 186,624£  223,966£   296,175£  406,407£   482,336£     496,804£    
CFR – HRA 283,242£  325,235£   397,755£  442,630£   466,732£     496,802£    
CFR – PFI Schemes 84,815£    80,661£     76,277£    71,663£     66,819£       61,745£      
Total CFR 554,681£  629,862£   770,207£  920,700£   1,015,887£  1,055,351£ 
Movement in CFR 64,796£    75,181£     140,345£  150,492£   95,187£       39,465£      
Movement in CFR represented by
Net financing need for the year (previous table) 73,624£    85,629£     156,747£  169,578£   116,765£     63,106£      
MEL Shareholder Injection 4,590£      -£               -£             -£               -£                -£               
Less Scheduled Debt Amortisation (9,494)£    (10,884)£    (12,018)£  (14,472)£    (16,734)£     (18,567)£    
Less net PFI Finance Lease Principal Payments (3,924)£    (4,154)£      (4,384)£    (4,614)£      (4,844)£       (5,074)£      
Movement in CFR 64,796£    70,591£     140,345£  150,492£   95,187£       39,465£      
Capital Financing Requirement (CFR)
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 340,871£  379,445£  458,024£  611,479£  775,282£     876,652£    
Actual/Expected change in Debt 38,574£    78,579£    153,456£  163,802£  101,370£     45,351£      
Other long-term liabilities (OLTL) at 1 April 88,739£    84,815£    80,661£    76,277£    71,663£       66,819£      
Actual/Expected change in OLTL (3,924)£    (4,154)£    (4,384)£    (4,614)£    (4,844)£       (5,074)£      
Actual/Expected Gross Debt at 31 March 464,260£  538,685£  687,756£  846,945£  943,471£     983,747£    
The Capital Financing Requirement 554,681£  629,862£  770,207£  920,700£  1,015,887£  1,055,351£ 
Under / (over) borrowing 90,421£    91,178£    82,451£    73,755£    72,416£       71,604£      
Deposits
Cash & Cash Equivalents 20,000£    20,000£    20,000£    20,000£    20,000£       20,000£      
Short-Term Investments 10,000£    -£             -£             -£             -£                -£               
Total Deposits 30,000£    20,000£    20,000£    20,000£    20,000£       20,000£      
Net Borrowing Requirement
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4. Prudential Indicators for External Debt 
4.1 Operational Boundary 
This is the limit beyond which external debt is not normally expected to exceed and will be the
focus of day to day treasury management.  Typically, this would be a similar figure to the CFR,
but may be lower or higher depending on the levels of actual debt.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly to the
value of the CFR for General Services and HRA combined, over the current financial
year and the following 4 financial years (2025/26 to 2029/30); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated to
equate directly to the in-year CFR for Other Long-Term Liabilities, given the known
contractual provisions for the repayment of debt within the Council’s two PPP
agreements. 
Should the Operational Boundary be breached, for example as a result of a decision taken to
borrow in advance (should market conditions indicate that it is prudent to do so), this will be
reported to Council at the next available opportunity. 
4.2 Authorised Limit of Total External Debt 
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2026/27 financial year has been calculated to equate
to the maximum value of the Underlying Borrowing Requirement in 2026/27.  This equates to
£693.930 million as outlined below. 
2025/26 2026/27 2027/28 2028/29 2029/30
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 549,201£  693,930£  849,037£  949,068£     993,606£    
Operational Boundary - Other long term liabilities 80,661£    76,277£    71,663£    66,819£       61,745£      
Total 629,862£  770,207£  920,700£  1,015,887£  1,055,351£ 
Operational Boundary
£000's
CFR - General Services at 31 March 2027 296,175£    
CFR - HRA at 31 March 2027 397,755£    
Authorised Limit for Borrowing 693,930£    
Authorised Limit for Borrowing
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5. Prudential Indicators for Treasury Management 
5.1 Upper limits on Fixed and Variable Interest Rates 
This indicator limits the amount of external debt that may be held at fixed or variable rates.  These
limits are proposed to be as follows:- 
5.2 Maturity Structure of Borrowing 
This indicator sets the upper and lower limits of the time scales within which external debt may be
held. 
The Treasury Management Code of Practice requires that LOBO’s with a call date in the next 12
months are classified as short-term borrowing rather than longer-term (10 year+) borrowing. 
In addition, the Code also recommends that where an authority’s debt is typically very long term
(i.e. for a period of greater than 10 years), that authorities should break down the period in excess
of 10 years into several ranges, for example 10 to 20 years, 20 to 30 years, etc. 
With the above in mind, the proposed upper and lower limits for each maturity band are shown
below, with the overall aim to ensure a spreading approach to avoid a cluster of high value loans
maturing/requiring refinancing within a short period of time. 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Upper Limits on Exposure to Fixed and Variable Interest Rates 2026/27
Interest rate exposures Upper
Limit
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5.4 Total Principal Sums Invested for Periods Longer than 365 Days 
This indicator relates to the total level of investments held for periods longer than 365 days. 
The current strategy as outlined in the body of these reports is to continue to cash-back the
Council’s balance sheet reserves.  It is expected that the majority of this will be in the form of fixed
term deposits and/or certificates of deposit.  Given expected reserve forecasts and the current
interest rate environment, in particular the short-medium term forecast for the Council’s Capital
Fund and HRA Reserve, the limit for prinicipal sums invested for > 365 days has been retained at
£70m. 
For its cash flow generated balances, the Council will seek to utilise its business reserve instant
access accounts and money market funds. 
5.5 Liability Benchmark 
The “Liability Benchmark” identifies future borrowing needs across the short, medium and longer
terms, against the maturity profile of the Council’s existing loan portfolio. 
The Council’s Liability Benchmark in graphical format is as shown below. 
Maturity structure of fixed interest rate borrowing 2026/27 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2026/27 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
Maturity Structure of Borrowing 2026/27
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
Limit £70m
Principal Sums Invested for > 365 Days
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There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’s existing loans that are still
outstanding in future years – shown as the stacked bar elements of the figure
above.
2 Loans CFR: this is calculated in accordance with the loans CFR definition in the
Prudential Code and projected into the future based on approved prudential
borrowing and planned Loans Fund advances/Loans Fund principal repayments. 
3 Net loans requirement: this shows the Council’s gross loan debt less treasury
management investments at the last financial year-end, projected into the future
and based on its approved prudential borrowing, planned Loans Fund principal
repayments and any other major cash flows (drawdowns/enhancement of
reserves) forecast.
4 Liability benchmark (or gross loans requirement): this equals net loans
requirement plus short-term liquidity/working capital allowance. 
The Liability Benchmark Indicator identifies the Council’s expected future capital financing
requirement, as driven by the Council’s approved Capital Plans – and therefore the Council’s
future borrowing needs; along with how this matches to the existing debt maturity profile.  It is
therefore a key tool to support the financing risk management of the capital financing
requirement. 
As can be noted from the figure above, the Council has a significant borrowing requirement
(which equates to £564.083 million) in the short-medium term, arising as a direct result of the
Council’s approved Capital Plans.  The proposed approach to securing this borrowing need for
the 2026/27 financial year is outlined in the main body of this report, Section 4.3. 
The Liability Benchmark also outlines the profile of the Council’s CFR over the medium-long term,
against the Council’s existing debt portfolio maturity profile.  As can be seen from the figure
above, the profile of the CFR movements in the medium-long term broadly matches the
movements in the Councils external debt portfolio over this period. 
£0
£200,000
£400,000
£600,000
£800,000
£1,000,000
£1,200,000
Total Am
ount (£'000)
Liability Benchmark
PWLB Loans Market Loans (excl LOBO loans)
LOBO Loans Existing Loan Debt Outstanding
Net Loans Requirement (forecast net loan debt) Loans CFR
Liability Benchmark (Gross Loans Requirement)
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The Debt Liability Benchmark will assist the Council with plotting the tenor of borrowing to finance
the Council’s approved capital plans that is undertaken in the remainder of 2025/26 and the
forthcoming 2026/27 period, to ensure that this aligns with the Council’s future expected CFR
profile and Liability Benchmark projections, taking into account the profile of existing loan
maturities as identified in the figure above. 
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Appendix 3 
Treasury Management Strategy Statement
and Annual Investment Strategy 
Midlothian Council
2026/27 
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INDEX 
1 INTRODUCTION ............................................................................................................................ 3
1.1 Background ............................................................................................................................................... 3
1.2 Reporting requirements ............................................................................................................................ 3
1.3 Treasury Management Strategy for 2026/27 ........................................................................................... 5
1.4 Training ...................................................................................................................................................... 5
1.5 Treasury management consultants .......................................................................................................... 6
2 THE CAPITAL PRUDENTIAL INDICATORS 2026/27 – 2029/30 ............................................. 7
2.1 Capital expenditure ................................................................................................................................... 7
2.2 The Council’s borrowing need (the Capital Financing Requirement) ...................................................... 8
3 Borrowing .................................................................................................................................... 11
3.1 Current portfolio position ......................................................................................................................... 11
3.2 Treasury Indicators: limits to borrowing activity ...................................................................................... 13
3.3 Prospects for interest rates ..................................................................................................................... 14
3.4 Borrowing strategy .................................................................................................................................. 16
3.5 Policy on borrowing in advance of need ................................................................................................. 19
3.6 Debt rescheduling ................................................................................................................................... 19
4 ANNUAL INVESTMENT STRATEGY ........................................................................................ 19
4.1 Investment policy ..................................................................................................................................... 20
4.2 Creditworthiness policy ........................................................................................................................... 22
4.3 Country and sector limits ......................................................................................................................... 23
4.4 Investment strategy ................................................................................................................................. 24
4.5 Investment risk benchmarking ................................................................................................................ 26
4.6 End of year investment report ................................................................................................................. 26
5 Appendices .................................................................................................................................. 27
5.1 APPENDIX: Economic Background ....................................................................................................... 28
5.2 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments .................................... 28
5.3 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 41
5.4 APPENDIX: Approved countries for investments .................................................................................. 47
5.5 APPENDIX: Treasury management scheme of delegation .................................................................. 48
5.6 APPENDIX: The treasury management role of the section 95 officer .................................................. 49 
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1 INTRODUCTION
1.1 Background
The main function of the treasury management service is the funding of the Council’s
capital plans.  These capital plans provide a guide to the borrowing need of the Council,
essentially the longer term cash flow planning to ensure that the Council can meet its
capital spending obligations.  This management of longer term cash may involve
arranging long or short term loans, or using longer term cash flow surpluses.   On
occasion any debt previously drawn may be restructured to meet Council risk or cost
objectives. 
The Council is required to operate a balanced budget, which broadly means that cash
raised during the year will meet cash expenditure.  As such, the second part of the treasury
management operation is to ensure that this cash flow is adequately planned, with cash
being available when it is needed.  Surplus monies are deposited with low risk
counterparties or instruments commensurate with the Council’s low risk appetite, providing
adequate liquidity initially before considering investment return. 
The contribution the treasury management function makes to the authority is critical, as the
balance of debt and investment operations ensure liquidity or the ability to meet spending
commitments as they fall due, either on day-to-day revenue or for larger capital projects. 
The treasury operations will see a balance of the interest costs of debt and the investment
income arising from cash deposits affecting the available budget.  Since cash balances
generally result from reserves and balances, it is paramount to ensure adequate security
of the sums invested, as a loss of principal will in effect result in a loss to the General Fund
Balance. 
Whilst any loans to third parties, commercial investment initiatives or other non-financial
investments will impact on the treasury function, these activities are generally classed as
non-treasury activities, (arising usually from capital expenditure),and are separate from the
day to day treasury management activities. 
CIPFA defines treasury management as: 
“The management of the local authority’s borrowing, investments and cash flows, its
banking, money market and capital market transactions; the effective control of the risks
associated with those activities; and the pursuit of optimum performance consistent with
those risks.” 
Whilst any commercial initiatives or loans to third parties will impact on the treasury
function, these activities are generally classed as non-treasury activities, (arising
usually from capital expenditure), and are separate from the day-to-day treasury
management activities 
1.2 Reporting requirements
1.2.1 Capital Strategy 
The CIPFA Prudential and Treasury Management Codes require all local authorities
to prepare an additional report, a capital strategy report, which provides the following: 
• a high-level long term overview of how capital expenditure, capital financing
and treasury management activity contribute to the provision of services
• an overview of how the associated risk is managed
• the implications for future financial sustainability 
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4
The aim of the capital strategy is to ensure that all elected members on the full council
fully understand the overall long-term policy objectives and resulting capital strategy
requirements, governance procedures and risk appetite. 
1.2.2 Treasury Management Reporting 
The Council is required to receive and approve, as a minimum, three main reports each
year, which incorporate a variety of polices, estimates and actuals.   
a) Prudential and treasury indicators and treasury strategy (this report) - The
first, and most important report covers:
• the capital plans (including prudential indicators) for 2025/26 to 2029/30;
• a policy for the statutory repayment of debt, (how residual capital expenditure
is charged to revenue over time);
• the treasury management strategy (how the investments and borrowings are
to be organised) for 2026/27, including treasury indicators; and 
• a permitted investment strategy for 2026/27 (the parameters on how
investments are to be managed). 
b) A mid year treasury management report – This will update members with
the progress of the capital position, amending prudential indicators as
necessary, and whether the actual treasury strategy is meeting the strategy
outlined in advance of the year, or whether any policies require revision. 
c) An annual treasury outturn report – This provides details of a selection of
actual prudential and treasury indicators for the previous financial year and
actual treasury operations compared to the estimates within the strategy. 
Scrutiny
The above reports are required to be adequately scrutinised before being
recommended to the Council.  This role is undertaken by the Audit Committee with this
report being presented to Audit Committee prior to consideration by Council.  Any
revisions arising from Audit Committee consideration of the report on 23 February 2026
will be verbally updated to Council before discussing the report on 24 February 2026. 
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1.3 Treasury Management Strategy for 2026/27
The strategy for 2026/27 covers two main areas: 
Capital issues
• the capital expenditure plans and the prudential indicators (Section 2 of this report);
• The policy for the statutory repayment of loans fund advance (Section 2.4 of this
report). 
Treasury management issues
• policy on use of external service providers (Section 1.5);
• the current treasury position (Section 3.1);
• treasury indicators which limit the treasury risk and activities of the Council (Section
3.2);
• prospects for interest rates (Section 3.3);
• the borrowing strategy (Section 3.4);
• policy on borrowing in advance of need (Section 3.5);
• debt rescheduling (Section 3.6);
• the investment strategy (Section 4.1); and
• creditworthiness policy (Section 4.2). 
These elements cover the requirements of the Local Government in Scotland Act 2003, the
CIPFA Prudential Code, the CIPFA Treasury Management Code and The Scottish
Government Local Authority (Capital Finance & Accounting) (Scotland) Regulations 2016.
1.4 Training
The CIPFA Code requires the responsible officer to ensure that members with responsibility
for treasury management receive adequate training in treasury management.  This
especially applies to members responsibe for scrutiny. 
Furthermore, pages 47 and 48 of the Code state that they expect “all organisations to have
a formal and comprehensive knowledge and skills or training policy for the effective
acquisition and retention of treasury management knowledge and skills for those
responsible for management, delivery, governance and decision making. 
Organisations need to consider how to assess whether treasury management staff and
board/ council members have the required knowledge and skills to undertake their roles
and whether they have been able to maintain those skills and keep them up to date. 
As a minimum, authorities should carry out the following to monitor and review knowledge
and skills: 
• Record attendance at training.
• Prepare tailored learning plans for treasury management officers and
board/council members.
• Require treasury management officers and board/council members to
undertake self-assessment against the required competencies. 
• Have regular communication with officers and board/council members,
encouraging them to highlight training needs on an ongoing basis.” 
In further support of the revised training requirements, CIPFA’s Better Governance Forum
and Treasury Management Network have produced a ‘self-assessment by members
responsible for the scrutiny of treasury management’, which is available from the CIPFA
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6
website to download.  This was presented to members of the Audit Committee and Council
as part of the Council’s Treasury Management 2021-22 Mid-Year Review Report. 
A formal record of Knowledge & Skills Schedule has been developed as part of the
Council’s Treasury Management Practices.  This will be periodically reviewed to assess
suitability, and updated to reflect ongoing training, knowledge and skills gained.  Similarly,
a formal record of the treasury management/capital finance training received by members
will also be periodically reviewed and updated. 
1.5 Treasury management consultants
The Council uses MUFG Corporate Markets (former Link, Treasury Solutions Limited) as
its external treasury management advisors. 
The Council recognises that responsibility for treasury management decisions remains with
the organisation at all times and will ensure that undue reliance is not placed upon our
external service providers.  All decisions will be undertaken with regards to all available
information, including, but not solely, our treasury advisers. 
It also recognises that there is value in employing external providers of treasury
management services in order to acquire access to specialist skills and resources. The
Council will ensure that the terms of their appointment and the methods by which their value
will be assessed are properly agreed and documented, and subjected to regular review. 
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7
2 THE CAPITAL PRUDENTIAL INDICATORS 2025/26 –
2029/30
The Council’s capital expenditure plans are the key driver of treasury management
activity.  The output of the capital expenditure plans is reflected in the prudential
indicators, which are designed to assist members’ overview and confirm capital
expenditure plans.
2.1 Capital expenditure
This prudential indicator is a summary of the Council’s capital expenditure plans,
both those agreed previously, and those forming part of this budget cycle.
The table below summarises the Capital Expenditure forecasts:- 
The table below shows how the Capital Expenditure forecasts are being financed
by capital or revenue resources.  Any shortfall of resources results in a funding
borrowing need.
Members are asked to approve the capital expenditure forecasts and the financing
of these forecasts:- 
Note: The above financing need excludes other long term liabilities, such as PFI
and leasing arrangements which already include borrowing instruments.  
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 17,218£    21,977£    71,726£    106,520£  84,850£    18,590£ 
Asset Management 13,334£    18,593£    19,262£    17,066£    14,250£    14,811£ 
Transport, Energy & Infrastructure 2,346£      5,821£      8,654£      2,233£      428£         428£      
Regeneration & Development 15,078£    13,343£    8,604£      8,963£      5,232£      3,050£   
Other 1,058£      465£         297£         180£         180£         180£      
Provision for return of contingencies -£              (1,194)£    (1,505)£    (2,714)£    (3,374)£    (2,624)£  
Total General Services 49,034£    59,004£    107,038£  132,248£  101,566£  34,436£ 
Total HRA 53,174£    59,999£    88,419£    69,783£    47,355£    48,724£ 
Combined Total 102,208£  119,003£  195,457£  202,031£  148,921£  83,160£ 
Table 1: Capital Expenditure
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 49,034£     59,004£    107,038£  132,248£  101,566£  34,436£ 
HRA 53,174£     59,999£    88,419£    69,783£    47,355£    48,724£ 
Total 102,208£   119,003£  195,457£  202,031£  148,921£  83,160£ 
Financed by:
Capital receipts 175£          -£             -£             -£             -£             -£           
Capital grants 25,191£     27,390£    24,588£    25,307£    19,833£    14,869£ 
Capital reserves -£               -£             -£             -£             -£             -£           
Developer/Other Contributions 3,218£       5,984£      14,122£    7,146£      12,323£    5,185£   
Net financing need for the year 73,624£     85,629£    156,747£  169,578£  116,765£  63,106£ 
Table 2: Capital Expenditure and Available Financing
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2.2 The Council’s borrowing need (the Capital Financing Requirement)
The second prudential indicator is the Council’s Capital Financing Requirement
(CFR).  The CFR is simply the total historic outstanding capital expenditure which
has not yet been paid for from either revenue or capital resources.  It is essentially
a measure of the Council’s underlying borrowing need.  Any capital expenditure
above, which has not immediately been paid for (financed), will increase the CFR.
The CFR does not increase indefinitely, as annual repayments from revenue need
to be made which reflect the useful life of capital assets financed from borrowing. 
From 1st April 2016, Local Authorities may choose whether to use scheduled debt
amortisation (loans pool charges) or another suitable method of calculation in order
to repay borrowing.
The CFR includes any other long term liabilities (e.g. PFI schemes, finance leases). 
Whilst these increase the CFR, and therefore the Council’s borrowing requirement,
these types of scheme already include a borrowing facility and so the Council is
not required to separately borrow for these schemes.  The Council currently has
£88.739m of such schemes within the CFR.  The Council is asked to approve the
CFR projections below: 
A key aspect of the regulatory and professional guidance is that elected members
are aware of the size and scope of any commercial activity in relation to the
authority’s overall financial position.  The capital expenditure figures shown in 2.1
and the details above demonstrate the scope of this activity and, by approving
these figures, consider the scale proportionate to the Authority’s remaining activity.
2.3 Liability Benchmark
A third prudential indicator is the Debt Liability Benchmark (LB).  The Authority is
required to estimate and measure the LB for the forthcoming financial year and
the following two financial years, as a minimum. 
There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’s existing loans that are still
outstanding in future years.
2 Loans CFR: this is calculated in accordance with the loans CFR definition
in the Prudential Code and projected into the future based on approved
prudential borrowing and planned Loans Fund advances/Loans Fund
principal repayments. 
3 Net loans requirement: this shows the Council’s gross loan debt less
treasury management investments at the last financial year-end, projected
into the future and based on its approved prudential borrowing, planned
Loans Fund principal repayments and any other major cash flows
(drawdowns/enhancement of reserves) forecast.
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 186,624£  223,966£   296,175£  406,407£   482,336£     496,804£    
CFR – HRA 283,242£  325,235£   397,755£  442,630£   466,732£     496,802£    
CFR – PFI Schemes 84,815£    80,661£     76,277£    71,663£     66,819£       61,745£      
Total CFR 554,681£  629,862£   770,207£  920,700£   1,015,887£  1,055,351£ 
Movement in CFR 64,796£    75,181£     140,345£  150,492£   95,187£       39,465£      
Movement in CFR represented by
Net financing need for the year (previous table) 73,624£    85,629£     156,747£  169,578£   116,765£     63,106£      
MEL Shareholder Injection 4,590£      -£               -£             -£               -£                -£               
Less Scheduled Debt Amortisation (9,494)£    (10,884)£    (12,018)£  (14,472)£    (16,734)£     (18,567)£    
Less net PFI Finance Lease Principal Payments (3,924)£    (4,154)£      (4,384)£    (4,614)£      (4,844)£       (5,074)£      
Movement in CFR 64,796£    70,591£     140,345£  150,492£   95,187£       39,465£      
Table 3: Capital Financing Requirement (CFR)
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4 Liability benchmark (or gross loans requirement): this equals net
loans requirement plus short-term liquidity/working capital allowance. 
2.4 Core funds and expected investment balances
The application of resources (capital receipts, reserves etc.) to either finance
capital expenditure or other budget decisions to support the revenue budget will
have an ongoing impact on investments unless resources are supplemented each
year from new sources (asset sales etc.).  Detailed below are estimates of the year-
end balances for each resource and anticipated day-to-day cash flow balances. 
*Working capital balances shown are estimated year-end; these may be higher
mid-year 
2.5 Statutory repayment of loans fund advances
Under the Local Government Finance Circular 7/2016, Council is now required to set
out its policy for the statutory repayment of loans fund advances prior to the start of
each financial year. The repayment of loans fund advances ensures that the Council
makes a prudent provision each year to pay off an element of the accumulated loans
fund advances made in previous financial years.
It is proposed to retain the methodology adopted in 2025/26 – that is as follows:-
New Assets
£0
£200,000
£400,000
£600,000
£800,000
£1,000,000
£1,200,000
Total Amount (£'000)
Liability Benchmark
PWLB Loans Market Loans (excl LOBO loans)
LOBO Loans Existing Loan Debt Outstanding
Net Loans Requirement (forecast net loan debt) Loans CFR
Liability Benchmark (Gross Loans Requirement)
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
HRA Balances 31,910£    29,510£    28,242£      26,329£      24,890£    23,978£ 
General Fund Balances 9,877£      7,000£      6,000£        6,000£        6,000£      6,000£   
Earmarked reserves 22,152£    13,767£  6,883£        -£               -£             -£           
Provisions 3,756£      3,656£      3,556£        3,456£        3,356£      3,256£   
Capital Fund 17,600£    18,193£    18,718£      18,918£      19,118£    19,318£ 
Total Reserves / Core Funds 85,295£    72,126£    63,399£      54,703£      53,364£    52,552£ 
Working capital* 35,126£    39,052£    39,052£      39,052£      39,052£    39,052£ 
Under/over borrowing 90,421£    91,178£    82,451£      73,755£      72,416£    71,604£ 
Expected investments 30,000£    20,000£    20,000£      20,000£      20,000£    20,000£ 
Reserve
Table 4: Balance Sheet Resources
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In accordance with Finance Circular 7/2016, for all advances made in relation to the
provision of a new asset, the policy will be to defer the commencement of the first
principal repayment of the loans fund advance until the financial year following the one
in which the asset is first available for use.
Prudent Repayment of Loans Fund Advances
Finance Circular 7/2016 provides a variety of options to Councils for the profiling of the
repayment of each loans fund advance, so long as the principle of prudence is
maintained.  There are 4 options available: (a) Asset Life method; (b) Statutory method;
(c) Depreciation method; and (d) Funding/income profile method.
In line with the policy adopted in 2025/26, the Asset Life method shall be used for those
assets in Table 5.
Table 5: Asset Classes adopting the “Asset Life” method
Infrastructure
Curren
Loans Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20 
The annual repayments under the “Asset Life” method for those asset classes as noted
above will be calculated using the asset lives and will use the annuity method, to
ensure consistency of approach with the Statutory method for all other asset classes
(see below).  The annuity interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund rate, which for
2025/26 is currently estimated to be 2.97%.
For all other asset classes, the policy will also be to profile the annual repayments
under the “Asset Life” method, with the profile also calculated using the annuity
method.  The annuity interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund rate, which for
2025/26 is currently estimated to be 2.97%.
Whilst neither the Depreciation nor the Funding/income profile methods are currently
proposed, Council officers will continue to monitor whether it is appropriate to use this
for future capital projects. 
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3 Borrowing
The capital expenditure plans set out in Section 2 provide details of the service activity of
the Council.  The treasury management function ensures that the Council’s cash is
organised in accordance with the the relevant professional codes, so that sufficient cash is
available to meet this service activity.  This will involve both the organisation of the cash
flow and, where capital plans require, the organisation of approporiate borrowing facilities. 
The strategy covers the relevant treasury / prudential indicators, the current and projected
debt positions and the annual investment strategy.
3.1 Treasury management portfolio position
The overall treasury management portfolio as at 31 March 2025 and for the position as at
30 January 2026 are shown below for both borrowing and investments.
Table 6: Portfolio Position 31 March 2025 and 30 January 2026 
The Council’s forward projections for borrowing and investments are summarised below.
The table shows the actual external debt (the treasury management operations), against
the underlying capital borrowing need (the Capital Financing Requirement - CFR),
highlighting any over or under borrowing. 
Within the range of prudential indicators there are a number of key indicators to ensure
that the Council operates its activities within well-defined limits.  One of these is that
the Council needs to ensure that its gross debt does not, except in the short term, exceed
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
PWLB Annuity               395 8.92%               332 8.92%
PWLB Maturity        333,502 3.11%        340,283 3.12%
PWLB EIP          10,000 4.49%          67,542 4.24%
LOBO          15,000 4.63%          15,000 4.63%
Market Loans          20,548 3.04%          19,866 3.04%
Total Loans        379,445 3.21%        443,024 3.34%
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
Bank Call Accounts               538 4.34%               683 3.51%
Money Market Funds          25,946 4.54%          19,689 3.88%
Bank Fixed Term Deposits                  -   n/a          10,000 4.18%
Total Deposits          26,484 4.54%          30,372 3.97%
30 January 202631 March 2025
31 March 2025 30 January 2026
Loan Type
Deposit Type
2024/25 2025/26 2026/27 2027/28 2028/29 2029/30
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 340,871£  379,445£  458,024£  611,479£  775,282£     876,652£    
Actual/Expected change in Debt 38,574£    78,579£    153,456£  163,802£  101,370£     45,351£      
Other long-term liabilities (OLTL) at 1 April 88,739£    84,815£    80,661£    76,277£    71,663£       66,819£      
Actual/Expected change in OLTL (3,924)£    (4,154)£    (4,384)£    (4,614)£    (4,844)£       (5,074)£      
Actual/Expected Gross Debt at 31 March 464,260£  538,685£  687,756£  846,945£  943,471£     983,747£    
The Capital Financing Requirement 554,681£  629,862£  770,207£  920,700£  1,015,887£  1,055,351£ 
Under / (over) borrowing 90,421£    91,178£    82,451£    73,755£    72,416£       71,604£      
Deposits
Cash & Cash Equivalents 20,000£    20,000£    20,000£    20,000£    20,000£       20,000£      
Short-Term Investments 10,000£    -£             -£             -£             -£                -£               
Total Deposits 30,000£    20,000£    20,000£    20,000£    20,000£       20,000£      
Table 7: Net Borrowing Requirement
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the total of the CFR in the preceding year plus the estimates of any additional CFR for
2026/27.
The Chief Financial Officer & Section 95 Officer reports that the Council complied with
this prudential indicator in the current year and does not envisage difficulties for the
future.  This view takes into account current commitments, existing plans, and the
proposals in this budget report.  
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3.2 Treasury Indicators: limits to borrowing activity
The operational boundary
This is the limit beyond which external debt is not normally expected to exceed.  In
most cases, this would be a similar figure to the CFR, but may be lower or higher
depending on the levels of actual debt.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly
to the in-year value of the CFR over the current and following 4 financial years
(2025/26 to 2029/30); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated
to equate directly to the in-year CFR for Other Long-Term Liabilities, given the
known contractual provisions for the repayment of debt within the Council’s two
PPP agreements. 
The authorised limit for external debt
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2026/27 financial year has been calculated to
equate to the maximum value of the Underlying Borrowing Requirement in 2026/27.  This
equates to £693.930 million as outlined below. 
2025/26 2026/27 2027/28 2028/29 2029/30
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 549,201£  693,930£  849,037£  949,068£     993,606£    
Operational Boundary - Other long term liabilities 80,661£    76,277£    71,663£    66,819£       61,745£      
Total 629,862£  770,207£  920,700£  1,015,887£  1,055,351£ 
Table 8: Operational Boundary
£000's
CFR - General Services at 31 March 2027 296,175£    
CFR - HRA at 31 March 2027 397,755£    
Authorised Limit for Borrowing 693,930£    
Table 9: Authorised Limit for Borrowing
458,024
611,479
775,282
876,652 922,002
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
£1,000,000
2025/26 2026/27 2027/28 2028/29 2029/30
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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3.3 Prospects for interest rates
The Council has appointed MUFG Corporate Markets as its treasury advisor and part
of their service is to assist the Council to formulate a view on interest rates. MUFG
provided the following forecasts for certainty rates (gilt yields plus 80 bps) on 22
December 2025. 
MUFG’s revised PWLB rate forecasts below are based on the Certainty Rate (the
standard rate minus 20 bps). 
Table 10: MUFG Interest Rate Forecasts 
In the second half of 2025, a combination of tepid growth (0.2% q/q GDP for Q2 and
0.1% q/q GDP for Q3), falling inflation (currently CPI is 3.2%), and a November Budget
that will place more pressure on the majority of households’ income, has provided an
opportunity for the Bank of England’s Monetary Policy Committee to further reduce
Bank Rate from 4.00% to 3.75% on 18 December. 
Surprisingly, to most market commentators, the recent steep fall in CPI inflation in one
month from 3.6% to 3.2% did not persuade most “dissenters” from the November vote
(Lombardelli, Greene, Mann and Pill) to switch to the rate-cutting side of the
Committee.  Instead, it was the Bank Governor, Andrew Bailey’s deciding vote which
resulted in a rate cut by the slimmest of margins, 5-4. 
Given the wafer-thin majority for a rate cut it was not unexpected to hear that although
rates would continue on a “gradual downward path”, suggesting a further rate cut or
cuts in the offing, MPC members want to assess incoming evidence on labour market
activity and wage growth.  Indeed, with annual wage growth still over 4.5%, the MPC
reiterated that the case for further rate cuts would be “a closer call”, and Governor
Bailey observed there is “limited space as Bank Rate approaches a neutral level”. 
Accordingly, the MUFG Corporate Markets forecast has been revised to price in a rate
cut in Q2 2026 to 3.50%, likely to take place in the wake of a significant fall in the CPI
inflation reading from 3.00% in March to 2.00% in April (as forecast by Capital
Economics), followed by a short lull through the summer whilst more data is garnered,
and then a further rate cut to 3.25% in Q4. 
However, threats to this central scenario abound.  What if wage increases remain
stubbornly high?  There are, after all, several sectors of the domestic economy,
including social care provision and the building/construction industries, where staff
shortages remain severe.  Moreover, by May 2026, following the local elections, there
will be better clarity on the leadership of the main UK political parties, which will
influence gilt markets …and will there be additional geo-political factors to also bake
in, particularly the Fed’s monetary policy decisions in 2026 and the ongoing battle to
lower rates whilst inflation remains close to 3.00%. 
Accordingly, MUFG’s updated central forecast is made with several caveats.  Whilst
the confidence that the central forecast for Bank Rate and the 5-year PWLB Certainty
Rate is robust, they have marginally brought forward the timing of the next rate cut(s). 
However, for the 10-, 25- and 50-years part of the gilt curve, the level of gilt issuance,
and the timing of its placement, will be integral to achieving a benign trading
Bank Rate 3.75% 3.50% 3.50% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25% 3.25%
3 month average earnings 3.80% 3.50% 3.50% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30%
6 month average earnings 3.80% 3.50% 3.50% 3.40% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30% 3.30%
12 month average earnings 3.90% 3.60% 3.60% 3.50% 3.40% 3.50% 3.50% 3.50% 3.50% 3.50% 3.60% 3.60% 3.60%
5 year PWLB 4.60% 4.50% 4.30% 4.20% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10% 4.10%
10 year PWLB 5.20% 5.00% 4.90% 4.80% 4.80% 4.70% 4.70% 4.70% 4.70% 4.60% 4.60% 4.60% 4.70%
25 year PWLB 5.80% 5.70% 5.60% 5.50% 5.50% 5.40% 5.30% 5.30% 5.30% 5.20% 5.20% 5.20% 5.20%
50 year PWLB 5.60% 5.50% 5.40% 5.30% 5.30% 5.20% 5.10% 5.10% 5.10% 5.00% 5.10% 5.00% 5.00%
MUFG Corporate Markets Interest Rate View
Mar-28 Jun-28 Sep-28 Dec-28 Mar-29Mar-26 Jun-26 Sep-26 Dec-26 Dec-27Sep-27Jun-27Mar-27
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environment.  That is not a “given”, and additionally, the inflation outlook and political
factors domestically and, crucially, in the US, are also likely to hold sway.  Matters
should be clearer by June in the UK, but the US mid-term elections are scheduled for
November. 
MUFG’s revised PWLB rate forecasts are based on the Certainty Rate (the standard
rate minus 20 bps) which has been accessible to most authorities since 1 November
2012.  The lower Housing Revenue Account (HRA) PWLB rate started on 15 June
2023 for those authorities with an HRA (standard rate minus 60 bps) and has recently
been announced as being extended into the 2026/27 financial year. 
Money market yield forecasts are based on expected average earnings by local
authorities for 3 to 12 months. 
A more detailed interest rate view and economic commentary is provided at
appendix 5.1. 
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3.4 Borrowing strategy 
Borrowing is undertaken to finance the Council’s approved Capital plans and to do so
in the most cost-effective way.  As can be noted from Table 3 of the main report, the
Council has a significant borrowing requirement across the current and forthcoming
four financial years (2025/26 to 2029/30). 
This TMIS provides for this capital investment to be underpinned by long-term
borrowing, recognising the current interest rate environment, the significant borrowing
requirement arising from the Council’s capital plans, and the long term benefits of de
risking the delivery and affordability of these capital plans by locking into the certainty
brought by PWLB fixed rate loans. 
The Council’s external loan debt at 31 March 2026 is projected to be £458.024
million.  Based on the Council’s historic and current approved Capital Plans, the
Underlying Borrowing Requirement (UBR) – which is the Council’s underlying need
to borrow for capital purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2026 is expected to equate to £549.201 million. 
This means that the Council is expected to be £91.177 million (17%) under-
borrowed at the end of the 2025/26 financial year i.e. the Council has funded the
majority (83%) of its underlying borrowing requirement as at 31 March 2026.  In the
current economic climate, this is a prudent approach which balances (a) de-risking the
longer term borrowing requirement at current longer term borrowing rates; against (b)
the current year and forthcoming financial year budget projections.  The Council has a
relatively low short-medium term exposure to refinancing risk and is therefore in a
strong position to plan its new borrowing requirements in advance, taking advantage of
any dips in longer-term borrowing rates from PWLB and other sources, and maintain a
low weighted average coupon rate on external debt.   
The Underlying Borrowing Requirement is projected to rise to £993.034 million by
31 March 2030 – more than double the current external debt portfolio value of
£443.024 million.  The profile of this, and the projected external loan portfolio to fund
the Underlying Borrowing Requirement over the period 2025/26 to 2029/30, is shown
in graphical format below. 
Figure 3: Loan Portfolio & Underlying Borrowing Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the curve at the time
of writing sitting at the shortest tenors (1-3 years @ c. 4.50%; certainty rate) with rates
trending upwards towards the 25-30 year tenor (high point of 6.03%; certainty rate)
before easing back slightly to sit at c. 5.79% (certainty rate) in the 50 year duration. 
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Current PWLB rates have generally increased by c. 20bps across the majority of the
interest rate curve from levels reported at the time of the 2025/26 TMIS to Council in
February 2025, and as noted in the TM Mid-Year Review Report to Council in
December 2025, are expected to remain elevated for longer, particularly at the
medium-longer end of the curve.  This reflects ongoing concerns around the stickiness
of inflation and international factors emanating from the Trump administration's fiscal,
tariff and geo-political policies which continue to play a significant role in market
expectations. 
The forward-looking Interest Rate Forecast from the Council's Treasury Advisers,
MUFG Corporate Markets, is as shown in Table 10 in Section 3.3 above, with Further
commentary on this is provided in Appendix 3 Section 3.3. 
As can be noted in Table 4 above, the yield curve is expected to remain bell shaped
over the short-medium term, with a gradual shift downwards of the entire curve by c.
30-40bps over the next 12 months, a further 10-20bps over the subsequent 12 months
and a further 10bps in the medium/longer end over the following 12 months of the
forecast period (so 50-60bps total). 
This is forecast to bring longer-term borrowing rates down from between 5.79%-
6.03%, to between:- 
• 5.60%-5.80% by March 2026;
• 5.30%-5.50% by March 2027; and
• 5.10%-5.30% by March 2028. 
Borrowing Strategy
The funding of the Council's in-year and forward CFR is typically for infrastructure with
long asset lives (50-60 years), and the tenor of PWLB and market loans are typically
drawn with this in mind. 
Given the Council's borrowing requirement across 2025/26 to 2029/30 as outlined in
Table 3, and the Interest Rate Forecasts as outlined in Table 4, consideration for any
new borrowing, to fund the Council's CFR, will seek to balance:- 
a) the security/certainty of current relatively high longer-term borrowing rates
of upwards of 5.60% in the 30-50 year duration (which are forecast to drop
by 30bps within one year and a total of 50bps within 24 months) and the
potential additional budgetary pressure that this brings in both the
short/medium and longer term; with 
b) the option to borrow initially for a shorter-term duration from PWLB or other
markets, for 3 to 5 years (at say c. 3.80-4.20% at the HRA rate), to allow
the Council to fund the immediate in-year borrowing requirement.  Based
on current interest rate forecasts (see Appendix 3 Section 3.3), this would
then allow the Council the option to refinance this borrowing at initial 3-5
year maturity with less expensive, longer term borrowing, e.g. a 45 to 47
year tenor in, say, 36 months at a forecast rate of c. 4.60-4.80% (HRA
Rate). 
Any further long-term borrowing that is undertaken to finance the current & future year
capital plans is expected to be sourced by drawing new PWLB loans at the Certainty
Rate (which has been available to the Council since 2012 and is priced at
Gilts+80bps), and/or the HRA rate.  The HRA rate is available to all Councils to fund
HRA capital expenditure, at a rate that is priced at Gilts+40bps, with an extension of
the availability of this rate beyond 31 March 2026 (and so into financial year 2026/27)
announced by the UK Government's Ministry of Housing, Communities & Local
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Government (MHCLG) on 28 January 2026 .  Other market-led longer-term borrowing
opportunities will be benchmarked against the prevailing PWLB rates to assess
whether they offer value to the Council. 
Council officers, in conjunction with MUFG, will continue to monitor daily long-term
borrowing rates in order to take advantage of any dips in the market or to de-risk any
change in the medium-longer term forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a 'forward dealing'
basis, and officers will continue to explore the viability of these loans as part of
securing the long term borrowing required to meet the Council's Underlying Borrowing
Requirement. 
Review of Capital Plans & Impact on Borrowing Strategy 
Both the General Services and HRA capital programmes are being kept under regular
review due to the effects of inflationary pressures, shortages of materials and labour,
and the ratios of financing costs to the net revenue streams.  The Council's borrowing
strategy will, therefore, also be regularly reviewed and then revised, if necessary, to
achieve optimum value and risk exposure in the medium-long-term. 
Treasury management limits on activity
There are three debt related treasury activity limits.  The purpose of these are to
restrain the activity of the treasury function within certain limits, thereby managing
risk and reducing the impact of any adverse movement in interest rates.  However,
if these are set to be too restrictive they will impair the opportunities to reduce costs
/ improve performance.  The indicators are:
• Upper limits on variable interest rate exposure. This identifies a
maximum limit for variable interest rates for borrowing based upon the
gross debt position, and variable interest rates for investments based
upon the total investment position;
• Upper limits on fixed interest rate exposure.  This is similar to the
previous indicator and covers a maximum limit on fixed interest rates
for both borrowing and investments;
• Maturity structure of borrowing. These gross limits are set to reduce the
Council’s exposure to large fixed rate sums falling due for refinancing,
and are required for upper and lower limits.
The Council is asked to approve the following treasury indicators and limits: 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Table 11: Upper Limits on Exposure to Fixed and Variable Interest Rates 2026/27
Interest rate exposures Upper
Limit
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3.5 Policy on borrowing in advance of need
The Council will not borrow more than or in advance of its needs purely in order to profit
from the investment of the extra sum borrowed.  Any decision to borrow in advance will be
within forward approved Capital Financing Requirement estimates (as detailed in Section
3.2) and will be considered carefully to ensure that value for money can be demonstrated
and that the Council can ensure the security of such funds. 
Risks associated with any borrowing in advance activity will be subject to prior
appraisal and subsequent reporting through the mid-year or annual reporting
mechanism.
3.6 Debt rescheduling 
As noted in the Mid-Year Review Report, the Council elected to reschedule (prematurely
repay) PWLB debt as follows:- 
• £12.700 million PWLB Maturity loan, original drawn date of 2 August 2007
and existing maturity date of 15 May 2053, at a fixed interest rate of 4.55% 
Any further debt rescheduling will be considered when the difference between the
refinancing rate and the redemption rate is most advantageous and the situation will be
continually monitored in order to take advantage of any perceived anomalies in the yield
curve.  The reasons for any rescheduling taking place would include: 
• the generation of cash savings at minimum risk;
• to reduce the average interest rate;
• to amend the maturity profile and/or the balance of volatility of the debt
portfolio.
Council officers will explore debt rescheduling opportunities with MUFG Treasury
Solutions; with only prudent and affordable debt rescheduling that considers both the
short and medium-longer term impact being considered.
Maturity structure of fixed interest rate borrowing 2026/27 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2026/27 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
Table 12: Maturity Structure of Borrowing 2026/27
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
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4 ANNUAL INVESTMENT STRATEGY
4.1 Investment policy
The Council’s investment policy implements the requirements of the following: - 
• Local Government Investments (Scotland) Regulations 2010, (and
accompanying Finance Circular 5/2010);
• CIPFA Treasury Management in the Public Services: Code of Practice and
Cross Sectoral Guidance Notes 2021 (“the Code”);
• CIPFA Treasury Management Guidance Notes 2021 
The Council’s investment priorities will be security first, portfolio liquidity second and then
yield, (return).  The Council will aim to achieve the optimum return (yield) on its investments
commensurate with proper levels of security and liquidity and with the Council’s risk
appetite. 
In the current economic climate, it is considered appropriate to maintain a degree of liquidity
to cover cash flow needs but to also consider “laddering” investments for periods up to 12
months with high credit rated financial institutions as we move down the interest rate yield
curve. 
The above regulations and guidance place a high priority on the management of risk. This
authority has adopted a prudent approach to managing risk and defines its risk appetite by
the following means: - 
1. The Council applies minimum acceptable credit criteria in order to generate
a list of highly creditworthy counterparties which also enables diversification
and thus avoidance of concentration risk.  The key ratings used to monitor
counterparties are the short-term and long-term ratings. 
2. Ratings will not be the sole determinant of the quality of an institution; it is
important to continually assess and monitor the financial sector on both a micro
and macro basis and in relation to the economic and political environments in
which institutions operate. The assessment will also take account of information
that reflects the opinion of the markets. To this end the Council will engage with
its advisors to maintain a monitor on market pricing such as “credit default
swaps” and overlay that information on top of the credit ratings. 
3. Other information sources used will include the financial press, share price
and other such information pertaining to the banking sector in order to establish
the most robust scrutiny process on the suitability of potential investment
counterparties. 
4. This authority has defined the list of types of investment instruments that are
permitted investments authorised for use in appendix 5.2.  Appendix 5.3
expands on the risks involved in each type of investment and the mitigating
controls. 
5. Lending limits, (maturity tenors), for each counterparty will be set through
applying the matrix table in Section 4.2 (maturity durations). 
6. Investments will only placed with counterparties from countries with a specified
minimum sovereign rating, (see paragraph 4.3). 
7. Lending per Country and Institution will be set through the application of the
criteria in Section 4.3 (amounts). 
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8. Transaction limits are set for each type of investment in appendix 5.2. 
9. This authority will set a limit for the amount of its investments which are invested
for longer than 365 days, (see paragraph 4.4). 
10. This authority has engaged external consultants, (see paragraph 1.5), to
provide expert advice on how to optimise an appropriate balance of security,
liquidity and yield, given the risk appetite of this authority in the context of the
expected level of cash balances and need for liquidity throughout the year. 
11. All investments will be denominated in sterling. 
However, this authority will also pursue value for money in treasury management and will
monitor the yield from investment income against appropriate benchmarks for investment
performance, (see paragraph 4.5). Regular monitoring of investment performance will be
carried out during the year.  
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4.2 Creditworthiness policy
This Council applies the creditworthiness service provided by MUFG Corporate Markets. 
This service employs a sophisticated modelling approach utilising credit ratings from the
three main credit rating agencies - Fitch, Moody’s and Standard and Poor’s.  The credit
ratings of counterparties are supplemented with the following overlays:- 
• credit watches and credit outlooks from credit rating agencies;
• CDS spreads to give early warning of likely changes in credit ratings;
• sovereign ratings to select counterparties from only the most creditworthy countries. 
This modelling approach combines credit ratings, credit watches and credit outlooks in a
weighted scoring system which is then combined with an overlay of CDS spreads for which
the end product is a series of colour coded bands which indicate the relative
creditworthiness of counterparties.  These colour codes are used by the Council to
determine the suggested duration for investments.   The Council will therefore use
counterparties within the following durational bands:- 
Note that the maximum suggested durations listed above have been extended by 1 year
(when compared to the suggested maximum durations provided by MUFG) for the Yellow,
Dark Pink, Light Pink, Purple, Blue and Orange categories, to allow flexibility around these
durations on the margins e.g. the placement of a 13 month fixed term deposit for a
counterparty rated Orange or Blue.  Equally, the maximum suggested duration for the Red
category has been extended by a month to 8 months, on the same basis.  A thorough
appraisal of the additional risk involved in extending the duration of any deposit (marginally)
beyond the maximum suggested by Capita, against any enhanced value to the portfolio,
will be undertaken prior to the placement of any deposit. 
The MUFG Corporate Markets creditworthiness service uses a wider array of information
than just primary ratings.  Furthermore, by using a risk weighted scoring system, it does not
give undue preponderance to just one agency’s ratings. 
Link Asset
Services
Colour Code
Maximum
Suggested
Duration for
Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent,  
Money Market Funds (MMF's), and collateralised deposits where
the collateral is UK Government Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25
Light Pink for Ultra Short Dated Bond Funds with a credit score of 1.5
*** Applies only to nationalised or semi-nationalised UK Banks
Table 13: Recommended Maximum
Durations for Investments
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Typically the minimum credit ratings criteria the Council use will be (Fitch or equivalents):- 
• Short term rating F1;
• Long term rating A-. 
There may be occasions when the counterparty ratings from one rating agency are
marginally lower than these ratings but may still be used.  In these instances consideration
will be given to the whole range of ratings available, or other topical market information, to
support their use. 
All credit ratings will be monitored weekly.  The Council is alerted to changes to ratings of
all three agencies through its use of the MUFG Corporate Markets creditworthiness service. 
• if a downgrade results in the counterparty / investment scheme no longer meeting
the Council’s minimum criteria, its further use as a new investment will be withdrawn
immediately;
• in addition to the use of credit ratings the Council will be advised of information in
movements in credit default swap spreads against the iTraxx benchmark and other
market data on a daily basis via its Passport website, provided exclusively to the
Council by MUFG Corporate Markets. Extreme market movements may result in
downgrade of an institution or removal from the Council’s lending list. 
Sole reliance will not be placed on the use of this external service.  In addition this Council
will also use market data and market information, information on sovereign support for
banks and the credit ratings of that supporting government.
UK banks – ring fencing
The largest UK banks, (those with more than £25bn of retail / Small and Medium-sized
Enterprise (SME) deposits), are required, by UK law, to separate core retail banking
services from their investment and international banking activities by 1st January 2019. This
is known as “ring-fencing”. Whilst smaller banks with less than £25bn in deposits are
exempt, they can choose to opt up. Several banks are very close to the threshold already
and so may come into scope in the future regardless.
Ring-fencing is a regulatory initiative created in response to the global financial crisis. It
mandates the separation of retail and SME deposits from investment banking, in order to
improve the resilience and resolvability of banks by changing their structure. In general,
simpler, activities offered from within a ring-fenced bank, (RFB), will be focused on lower
risk, day-to-day core transactions, whilst more complex and “riskier” activities are required
to be housed in a separate entity, a non-ring-fenced bank, (NRFB). This is intended to
ensure that an entity’s core activities are not adversely affected by the acts or omissions of
other members of its group.
While the structure of the banks included within this process may have changed, the
fundamentals of credit assessment have not. The Council will continue to assess the new-
formed entities in the same way that it does others and those with sufficiently high ratings,
(and any other metrics considered), will be considered for investment purposes.
4.3 Country and sector limits
The Council has determined that it will only use approved counterparties from the UK, or
approved counterparties from other countries with a minimum sovereign credit rating of AA-
from Fitch.
The list of countries that qualify using the above criteria as at the date of this report are
shown in Appendix 5.4.  This list will be added to, or deducted from, by officers should
ratings change in accordance with this policy.
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The Council will avoid a concentration of investments in too few counterparties or countries
by adopting a spreading approach to investing whereby no more than £30 million will be
invested in Lloyds Banking Group and the NatWest (Royal Bank of Scotland) Group, £15
million in any other UK counterparty, and £15 million in any one counterparty, group or
country outwith the UK.
4.4 Investment strategy
Current Deposits 
As at 30 January 2025, the Council’s deposits were as shown in Table 14 below:- 
Table 14: Council’s deposits at 30 January 2025 
Counterparty Amount
£000’s
Security
Long/Short
Term Rating*
(Colour)**
Liquidity Yield UK Local
Authority
Investment***
£000’s
MMF
Aberdeen 1,683 AAAmmf
(Yellow) Instant Access 3.86% 1,598,647
MMF
Federated 14,650 AAAmmf
(Yellow) Instant Access 3.86% 1,995,304
MMF
LGIM 3,357 AAAmmf
(Yellow) Instant Access 3.86% 608,296
Bank of Scotland
Call Account 622 AA-/F1+
(Orange) Instant Access 3.51% 351,953
Handelsbanken AB
Call Account 20 AA/F1+
(Orange) Instant Access 3.65% 103,416
Lloyds Banking Group
Corporate Markets 10,000 AA-/F1
(Orange)
Start: 29 Apr 2025
End: 29 Apr 2026 4.18% 182,632
Total 30,372    4,840,248 
* Credit Rating from Fitch
** Colour represents maximum recommended duration for deposit per MUFG Corporate Markets
Credit Scoring methodology – see Appendix 2.
*** As at 31 December 2025 
In-house funds. Investments will be made with reference to the core balance and cash
flow requirements and the outlook for short-term interest rates (i.e., rates for investments
up to 12 months, with the yield curve reducing the further out deposits are placed). 
While an element of cash balances are required in order to manage the ups and downs of
cash flow, where cash sums can be identified that could be invested for longer periods, the
value to be obtained from longer term investments will be carefully assessed. 
• If it is thought that Bank Rate is likely to fall within that time period,
consideration will be given to locking in higher rates currently obtainable, for
longer periods, where this is possible within the Council’s day-to-day and
monthly cashflow projections;
• Conversely, if it is thought that Bank Rate is likely to rise significantly within
the time horizon being considered (unlikely in the current climate), then
consideration will be given to keeping most investments as being short term
or variable. 
Investment returns expectations
The current forecast shown in paragraph 3.3, includes a forecast for Bank Rate to reduce
from the current level of 3.75% at the time of writing (30 January 2026) to 3.25% by the end
of the forecast time horizon (December 2027). 
The suggested budgeted investment earnings rates for returns on investments placed for
periods up to about three months during each financial year are as shown in Table 15: -
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Table 15: Suggested budgeted average earnings per annum 
Average earnings in
each year 
2025/26 (residual) 3.80%
2026/27 3.40%
2027/28 3.30%
2028/29 3.30%
2029/30 3.50%
Long term later years 3.50% 
As there are so many variables at this time, caution must be exercised in respect of all
interest rate forecasts.
Investment treasury indicator and limit - total principal funds invested for greater than
365 days. These limits are set with regard to the Council’s liquidity requirements and
expected usable reserve forecasts, and are based on the availability of funds after each
year-end. 
The Council is asked to retain the following treasury indicator and limit: - 
For its cash flow generated balances, the Council will seek to utilise its business reserve
instant access accounts and money market funds. 
4.5 Environmental, Social and Governance Criteria in Credit & Counterparty Policies
(Treasury Management Practice 1) 
The inclusion of ESG criteria continues to be an emerging area in the Local Authority
environment which will require ongoing monitoring. 
For the 2026/27 financial year, the Council’s priorities of security, liquidity and then yield
remain paramount and unchanged (and in that order), with ESG criteria an added 4th
element to consider in the decision making process. 
For short term investments with counterparties, this Council utilises the MUFG
creditworthiness service which uses the ratings provided by Fitch, Moody’s and Standard
& Poor’s to assess creditworthiness, which in themselves include analysis of ESG factors,
and specifically the “G” element, when assigning ratings.  Of the 3 elements of ESG, the
most important element when considering treasury deposits is the Governance aspect –
given the majority of treasury deposits undertaken by Midlothian Council are naturally short
dated in duration, poor governance can have a more immediate impact on the financial
circumstances of an entity and potential for a default event that could impact the amount of
principal returned on the deposit. 
Those financial institutions viewed as having poor/weak corporate governance are
generally less well credit rated in the first instance or have a higher propensity for being
subject to negative rating action, and the Council’s existing creditworthiness policy will
therefore take this into account. 
Environment and Social factors are also important, but relate more to the long-term impact. 
Council should note that in relation to the security aspect of Treasury deposits, placing an
undue weight on the Environmental and Social factors in the decision making process could
have an adverse effect of limiting the list of potential counterparty options, thus decreasing
diversification.  This could then in turn lead to a widening of credit (security) criteria, or those
Limit £70m
Principal Sums Invested for > 365 Days
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with a stronger “ESG” performance, in order to restore a balance of diversification across
the deposit portfolio, potentially increasing credit risk – and placing the cornerstone of
prudent investing at risk. 
The inclusion of ESG criteria therefore remains an area which requires ongoing review. 
Council officers, in conjunction with the Council’s treasury advisers MUFG, will therefore
continue to monitor and assess ongoing developments and emerging standards in this
area, and methods in which the Council can incorporate ESG factors into our
creditworthiness assessment process, and report back to Council accordingly. 
4.6 Investment risk benchmarking
The Council will use an investment benchmark to assess the investment performance of its
investment portfolio of 6 month SONIA compounded.  The Council also participates in
Investment Benchmarking groups with MUFG Corporate Markets whereby performance
with other Benchmarking club members and the wider Scottish and UK Local Authority
Investment benchmarking is compared. 
4.7 End of year investment report
At the end of the financial year, the Council will report on its investment activity as part of
its Annual Treasury Report.
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5 Appendices 
1. Economic background
2. Treasury Management Practice 1 – Permitted Investments
3. Treasury Management Practice 1 – Credit and Counterparty Risk Management
4. Approved countries for investments
5. Treasury management scheme of delegation
6. The treasury management role of the section 95 officer 
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5.6 APPENDIX: Economic Background
The first half of 2025/26 saw:- 
- A 0.3% pick up in GDP for the period April to June 2025. More recently,
the economy flatlined in July, with higher taxes for businesses restraining
growth, but picked up to 0.1% m/m in August before falling back by 0.1%
m/m in September.
- The 3m/yy rate of average earnings growth excluding bonuses has fallen
from 5.5% to 4.6% in September.
- CPI inflation has ebbed and flowed but finished September at 3.8%, whilst
core inflation eased to 3.5%.
- The Bank of England cut interest rates from 4.50% to 4.25% in May, and
then to 4% in August (and subsequently to 3.75% in December).
- The 10-year gilt yield fluctuated between 4.4% and 4.8%, ending the half
year at 4.70% (before falling back to 4.43% in early November). 
From a GDP perspective, the financial year got off to a bumpy start with the 0.3% m/m fall
in real GDP in April as front-running of US tariffs in Q1 (when GDP grew 0.7% on the
quarter) weighed on activity. Despite the underlying reasons for the drop, it was still the
first fall since October 2024 and the largest fall since October 2023. However, the
economy surprised to the upside in May and June so that quarterly growth ended up
0.3% q/q (subsequently revised down to 0.2% q/q). Nonetheless, the 0.0% m/m change
in real GDP in July, followed by a 0.1% m/m increase in August and a 0.1% decrease in
September will have caused some concern.  GDP growth for 2025 - 2028 is currently
forecast by the Office for Budget Responsibility to be in the region of 1.5%. 
Sticking with future economic sentiment, the composite Purchasing Manager Index (PMI)
for the UK increased to 52.2 in October.  The manufacturing PMI output balance
improved to just below 50 but it is the services sector (52.2) that continues to drive the
economy forward.  Nonetheless, the PMIs suggest tepid growth is the best that can be
expected in the second half of 2025 and the start of 2026.  Indeed, on 13 November we
heard that GDP for July to September was only 0.1% q/q. 
Turning to retail sales volumes, and the 1.5% year-on-year rise in September,
accelerating from a 0.7% increase in August, marked the highest gain since April. On a
monthly basis, retail sales volumes rose 0.5%, defying forecasts of a 0.2% fall, following
an upwardly revised 0.6% gain in August. Household spending remains surprisingly
resilient, but headwinds are gathering. 
Prior to the November Budget, the public finances position looked weak.  The £20.2 billion
borrowed in September was slightly above the £20.1 billion forecast by the OBR.  For the
year to date, the £99.8 billion borrowed is the second highest for the April to September
period since records began in 1993, surpassed only by borrowing during the COVID-19
pandemic.  The main drivers of the increased borrowing were higher debt interest costs,
rising government running costs, and increased inflation-linked benefit payments, which
outweighed the rise in tax and National Insurance contributions.   
Following the 26 November Budget, the Office for Budget Responsibility (OBR) calculated
the net tightening in fiscal policy as £11.7bn (0.3% of GDP) in 2029/30, smaller than the
consensus forecast of £25bn. It did downgrade productivity growth by 0.3%, from 1.3% to
1.0%, but a lot of that influence was offset by upgrades to its near-term wage and inflation
forecasts. Accordingly, the OBR judged the Chancellor was going to achieve her
objectives with £4.2bn to spare. The Chancellor then chose to expand that headroom to
£21.7bn, up from £9.9bn previously. 
Moreover, the Chancellor also chose to raise spending by a net £11.3bn in 2029/30. To
pay for that and to increase n headroom, she raised taxes by £26.1bn in 2029/30.  The
biggest revenue-raisers were the freeze in income tax thresholds from 2028/29 (+£7.8bn)
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and the rise in NICs on salary-sacrifice pension contributions (+£4.8bn). The increase in
council tax for properties worth more than £2.0m will generate £0.4bn. 
The weakening in the jobs market looked clear in the spring. May’s 109,000 m/m fall in
the PAYE measure of employment was the largest decline (barring the pandemic) since
the data began and the seventh in as many months. The monthly change was revised
lower in five of the previous seven months too, with April’s 33,000 fall revised down to a
55,000 drop. More recently, however, the monthly change was revised higher in seven of
the previous nine months by a total of 22,000. So instead of falling by 165,000 in total
since October, payroll employment is now thought to have declined by a smaller 153,000.
Even so, payroll employment has still fallen in nearly all the months since the Chancellor
announced the rises in National Insurance Contributions (NICs) for employers and the
minimum wage in the October 2024 Budget. The number of job vacancies in the three
months to November 2025 stood at 729,000 (the peak was 1.3 million in spring 2022). All
this suggests the labour market continues to loosen, albeit at a slow pace. 
A looser labour market is driving softer wage pressures. The 3m/yy rate of average
earnings growth excluding bonuses has fallen from 5.5% in April to 4.6% in September
(still at that level in November). The rate for the private sector has slipped just below 4%
as the year end approaches. 
CPI inflation remained at 3.8% in September but dropped to 3.2% by November.  Core
inflation also fell to 3.2% by November while services inflation fell to 4.4%. Nonetheless, a
further loosening in the labour market and weaker wage growth may be a requisite to UK
inflation coming in below 2.0% by 2027.   
An ever-present issue throughout recent months has been the pressure being exerted on
medium and longer dated gilt yields. The yield on the 10-year gilt moved sideways in the
second quarter of 2025, rising from 4.4% in early April to 4.8% in mid-April following wider
global bond market volatility stemming from the “Liberation Day” tariff announcement, and
then easing back as trade tensions began to de-escalate. By the end of April, the 10-year
gilt yield had returned to 4.4%. In May, concerns about stickier inflation and shifting
expectations about the path for interest rates led to another rise, with the 10-year gilt yield
fluctuating between 4.6% and 4.75% for most of May. Thereafter, as trade tensions
continued to ease and markets increasingly began to price in looser monetary policy, the
10-year yield edged lower, and ended June at 4.50%. 
More recently, the yield on the 10-year gilt rose from 4.46% to 4.60% in early July as
rolled-back spending cuts raised fiscal concerns. Although the spike proved short lived, it
highlighted the UK’s fragile fiscal position. In an era of high debt, high interest rates and
low GDP growth, the markets are now more sensitive to fiscal risks than before the
pandemic. During August, long-dated gilts underwent a particularly pronounced sell-off,
climbing 22 basis points and reaching a 27-year high of 5.6% by the end of the month.
While yields have since eased back, the market sell-off was driven by investor concerns
over growing supply-demand imbalances, stemming from unease over the lack of fiscal
consolidation and reduced demand from traditional long-dated bond purchasers like
pension funds. For 10-year gilts, by late September, sticky inflation, resilient activity data
and a hawkish Bank of England kept yields elevated over 4.70% although by late
December had fallen back again to a little over 4.50%. 
The FTSE 100 fell sharply following the “Liberation Day” tariff announcement, dropping by
more than 10% in the first week of April - from 8,634 on 1 April to 7,702 on 7 April.
However, the de-escalation of the trade war coupled with strong corporate earnings led to
a rapid rebound starting in late April. As a result, the FTSE 100 ended June at 8,761,
around 2% higher than its value at the end of March and more than 7% above its level at
the start of 2025. Since then, the FTSE 100 has enjoyed a further 4% rise in July, its
strongest monthly gain since January and outperforming the S&P 500. Strong corporate
earnings and progress in trade talks (US-EU, UK-India) lifted share prices and the index
hit a record 9,321 in mid-August, driven by hopes of peace in Ukraine and dovish signals
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from Fed Chair Powell. September proved more volatile and the FTSE 100 closed
September at 9,350, 7% higher than at the end of Q1 and 14% higher since the start of
2025. Future performance will likely be impacted by the extent to which investors’ global
risk appetite remains intact, Fed rate cuts, resilience in the US economy, and AI optimism.
A weaker pound will also boost the index as it inflates overseas earnings.  In early
November, the FTSE100 climbed to a record high just above 9,900.  By late December,
the index had clung on to most of those gains standing at 9,870 on 23 December. 
MPC meetings: 8 May, 19 June, 7 August, 18 September, 6 November,  December
2025 
There were six Monetary Policy Committee (MPC) meetings held between April and
December. In May, the Committee cut Bank Rate from 4.50% to 4.25%, while in June
policy was left unchanged. In June’s vote, three MPC members (Dhingra, Ramsden and
Taylor) voted for an immediate cut to 4.00%, citing loosening labour market conditions.
The other six members were more cautious, as they highlighted the need to monitor for
“signs of weak demand”, “supply-side constraints” and higher “inflation expectations”,
mainly from rising food prices. By repeating the well-used phrase “gradual and careful”,
the MPC continued to suggest that rates would be reduced further. 
In August, a further rate cut was implemented.  However, a 5-4 split vote for a rate cut to
4.00% laid bare the different views within the Monetary Policy Committee, with the
accompanying commentary noting the decision was “finely balanced” and reiterating that
future rate cuts would be undertaken “gradually and carefully”.  Ultimately, Governor
Bailey was the casting vote for a rate cut but with the CPI measure of inflation expected to
reach at least 4% later this year, the MPC was wary of making any further rate cuts until
inflation begins its slow downwards trajectory back towards 2%. 
With wages still rising by just below 5%, it was no surprise that the September meeting
saw the MPC vote 7-2 for keeping rates at 4% (Dhingra and Taylor voted for a further
25bps reduction).  Moreover, the Bank also took the opportunity to announce that they
would only shrink its balance sheet by £70bn over the next 12 months, rather than
£100bn. The repetition of the phrase that “a gradual and careful” approach to rate cuts is
appropriate suggested the Bank still thought interest rates will fall further. 
At the 6 November meeting, Governor Bailey was once again the deciding vote, keeping
Bank Rate at 4% but hinting strongly that a further rate cut was imminent if data
supported such a move.  By 18 December, with November CPI inflation having fallen to
3.2%, and with Q2 GDP revised down from 0.3% q/q to only 0.2% q/q, and Q3 GDP
stalling at 0.1%, the MPC voted by 5-4 to cut rates further to 3.75%.  However, Governor
Bailey made it clear that any further reductions would require strong supporting data, and
the pace of any further decreases would be slow compared to recent months.  The
markets expect Bank Rate to next be cut in April 2026. 
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5.7 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments 
This Council is asked to approve the following forms of investment instrument for use as
permitted investments as set out in tables 1.1-1.4. 
Treasury risks
All the investment instruments in tables 1.1-1.4 are subject to the following risks:- 
1. Credit and counter-party risk: this is the risk of failure by a counterparty (bank or
building society) to meet its contractual obligations to the organisation particularly
as a result of the counterparty’s diminished creditworthiness, and the resulting
detrimental effect on the organisation’s capital or current (revenue) resources.
There are no counterparties where this risk is zero although AAA rated
organisations have the highest, relative, level of creditworthiness. 
2. Liquidity risk: this is the risk that cash will not be available when it is needed.  
While it could be said that all counterparties are subject to at least a very small level
of liquidity risk as credit risk can never be zero, in this document, liquidity risk has
been treated as whether or not instant access to cash can be obtained from each
form of investment instrument.  However, it has to be pointed out that while some
forms of investment e.g. gilts, CDs, corporate bonds can usually be sold
immediately if the need arises, there are two caveats: - a.  cash may not be available
until a settlement date up to three days after the sale  b.  there is an implied
assumption that markets will not freeze up and so the instrument in question will
find a ready buyer.  The column in tables 1.1-1.4 headed as ‘market risk’ will show
each investment instrument as being instant access, sale T+3 = transaction date
plus 3 business days before you get cash, or term i.e. money is locked in until an
agreed maturity date. 
3. Market risk: this is the risk that, through adverse market fluctuations in the value
of the principal sums an organisation borrows and invests, its stated treasury
management policies and objectives are compromised, against which effects it has
failed to protect itself adequately.  However, some cash rich local authorities may
positively want exposure to market risk e.g. those investing in investment
instruments with a view to obtaining a long term increase in value. 
4. Interest rate risk: this is the risk that fluctuations in the levels of interest rates create
an unexpected or unbudgeted burden on the organisation’s finances, against which
the organisation has failed to protect itself adequately.  This authority has set limits
for its fixed and variable rate exposure in its Treasury Indicators in this report (see
Section 3.4). 
5. Legal and regulatory risk: this is the risk that the organisation itself, or an
organisation with which it is dealing in its treasury management activities, fails to
act in accordance with its legal powers or regulatory requirements, and that the
organisation suffers losses accordingly.   
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Controls on treasury risks
1. Credit and counter-party risk: this authority has set minimum credit criteria to
determine which counterparties and countries are of sufficiently high
creditworthiness to be considered for investment purposes.  See Sections 4.2 and
4.3. 
2. Liquidity risk: this authority has a cash flow forecasting model to enable it to
determine how long investments can be made for and how much can be invested. 
3. Market risk: this authority does not purchase investment instruments which are
subject to market risk in terms of fluctuation in their value. 
4. Interest rate risk: this authority manages this risk by having a view of the future
course of interest rates and then formulating a treasury management strategy
accordingly which aims to maximise investment earnings consistent with control of
risk or alternatively, seeks to minimise expenditure on interest costs on borrowing. 
See Section 4.4. 
5. Legal and regulatory risk: this authority will not undertake any form of investing
until it has ensured that it has all necessary powers and also complied with all
regulations. 
Unlimited investments 
Regulation 24 states that an investment can be shown in tables 1 / 2 as being ‘unlimited’ in
terms of the maximum amount or percentage of the total portfolio that can be put into that
type of investment.  However, it also requires that an explanation must be given for using
that category.  The authority has given the following types of investment an unlimited
category: - 
1. Debt Management Agency Deposit Facility.  This is considered to be the
lowest risk form of investment available to local authorities as it is operated
by the Debt Management Office which is part of H.M. Treasury i.e. the UK
Government’s sovereign rating stands behind the DMADF.  It is also a deposit
account and avoids the complications of buying and holding Government
issued treasury bills or gilts. 
2. High credit worthiness banks and building societies.  See paragraph 4.2
for an explanation of this authority’s definition of high credit worthiness.  While
an unlimited amount of the investment portfolio may be put into banks and
building societies with high credit worthiness, the authority will ensure
diversification of its portfolio ensuring that no more than £15 million can be
placed with any one institution or group at any one time, other than the Bank
of Scotland or Royal Bank of Scotland where the limit is £30 million. 
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Objectives of each type of investment instrument
Regulation 25 requires an explanation of the objectives of every type of investment
instrument which an authority approves as being ‘permitted’.
1. DEPOSITS
The following forms of ‘investments’ are actually more accurately called deposits as cash
is deposited in an account until an agreed maturity date or is held at call. 
a) Debt Management Agency Deposit Facility.  This offers the lowest risk form of
investment available to local authorities as it is effectively an investment placed with the
Government.  It is also easy to use as it is a deposit account and avoids the
complications of buying and holding Government issued treasury bills or gilts.  As it is
low risk it also earns low rates of interest.  However, it is very useful for authorities
whose overriding priority is the avoidance of risk.  The longest period for a term deposit
with the DMADF is 6 months. 
b) Term Deposits – Local Authorities.  They are quasi-Government bodies with low
counterparty and value risk.  Typical deposit terms vary from 1 month to 2 years, with
longer term deposits offering an opportunity to increase investment returns by locking
in high rates ahead of an expected fall in the level of interest rates.  At other times,
longer term rates can offer good value when the markets incorrectly assess the speed
and timing of interest rate increases.  This form of investing therefore, offers a lot of
flexibility and typically higher earnings than the DMADF.  Where it is restricted is that
once a longer term investment is made, that cash is locked in until the maturity date
other than with agreement of the counterparty, at which point penalties would typically
apply.
c) Call accounts with high credit worthiness banks and building societies.  See
Section 4.2 for an explanation of this authority’s definition of high credit worthiness. 
These typically offer a much higher rate of return than the DMADF and now that
measures have been put in place to avoid over reliance on credit ratings, the authority
feels much more confident that the residual risks around using such banks and building
societies are at a low, reasonable and acceptable level. There is instant access to
recalling cash deposited (or short-dated notice e.g. 15-30 days).  This generally means
accepting a lower rate of interest than that which could be earned from the same
institution by making a term deposit (see 1d below).  However, there are a number of
call accounts which at the time of writing, offer rates 2 – 3 times more than term deposits
with the DMADF.  Some use of call accounts is highly desirable to ensure that the
authority has ready access to cash when needed to pay bills. 
d) Term deposits with high credit worthiness banks and building societies.  The
objectives are as for 1c.  These offer a much higher rate of return than the DMADF and
deposits made with other Local Authorities (dependent upon term) and, similar to 1c,
now that measures have been put in place to avoid over reliance on credit ratings, the
authority feels much more confident that the residual risks around using such banks
and building societies are at a low, reasonable and acceptable level.  This is the most
widely used form of investing used by local authorities.  The authority will ensure
diversification of its portfolio of deposits ensuring that no more than £15 million is
invested with any (non-nationalised) UK counterparty, and no more than £15 million is
invested with any other non-UK counterparty, group or country.  In addition, longer term
deposits offer an opportunity to increase investment returns by locking in high rates
ahead of an expected fall in the level of interest rates.  At other times, longer term rates
can offer good value when the markets incorrectly assess the speed and timing of
interest rate increases.  This form of investing therefore, offers a lot of flexibility and
higher earnings than the DMADF.  Where it is restricted is that once a longer term
investment is made, that cash is locked in until the maturity date. 
e) Fixed term deposits with variable rate and variable maturities (structured
deposits).  This encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
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this area, this is a generic title for all structured deposits so as to provide councils with
greater flexibility to adopt new instruments as and when they are brought to the market. 
This line encompasses ALL types of structured deposits.  There has been considerable
change in the types of structured deposits brought to the market over the last few years,
some of which are already no longer available.  In view of the fluidity of this area, this is
a generic title for all structured deposits so as to provide greater flexibility to adopt new
instruments as and when they are brought to the market.
2. DEPOSITS WITH COUNTERPARTIES CURRENTLY IN RECEIPT OF UK
GOVERNMENT SUPPORT / OWNERSHIP
These banks offer another dimension of creditworthiness in terms of UK Government
backing through either direct (partial or full) ownership.  The view of this authority is that
such backing makes these banks attractive institutions with whom to place deposits, and
that will remain our view if the UK sovereign rating were to be downgraded in the coming
year. 
a. Call accounts.  As for 1c. but UK Government stated support implies that the UK
Government stands behind these banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the
continuity of such institutions.  This authority feels this indicates a low and
acceptable level of residual risk. 
b. Term deposits with high credit worthiness banks which are fully or semi
nationalised. As for 1d. but Government ownership partial or full implies that the UK
Government stands behind this bank and will be deeply committed to providing
whatever support that may be required to ensure the continuity of that bank.  This
authority considers   this indicates a low and acceptable level of residual risk. 
c. Fixed term deposits with variable rate and variable maturities (structured
deposits).  As for 1e but UK Government stated support implies that the UK
Government stands behind eligible banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the continuity
of such institutions.  This authority feels this indicates a low and acceptable level of
residual risk.  This line encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
this area, this is a generic title for all structured deposits so as to provide greater
flexibility to adopt new instruments as and when they are brought to the market.  
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3. COLLECTIVE INVESTMENT SCHEMES STRUCTURED AS OPEN ENDED
INVESTMENT COMPANIES (OEICS)
a. Government liquidity funds.  These are the same as money market funds (see
below) but only invest in government debt issuance with highly rated governments.  Due
to the higher quality of underlying investments, they offer a lower rate of return than
MMFs.  However, their net return is typically on a par with the DMADF, but with instant
access. 
b. Money Market Funds (MMFs).  By definition, MMFs are AAA rated and are widely
diversified, using many forms of money market securities including types which this
authority does not currently have the expertise or capabilities to hold directly.  However,
due to the high level of expertise of the fund managers and the huge amounts of money
invested in MMFs, and the fact that the weighted average maturity (WAM) cannot
exceed 60 days, MMFs offer a combination of high security, instant access to funds,
high diversification and good rates of return compared to equivalent instant access
facilities. They are particularly advantageous in falling interest rate environments as
their 60 day WAM means they have locked in investments earning higher rates of
interest than are currently available in the market.  MMFs also help an authority to
diversify its own portfolio as e.g. a £2m investment placed directly with HSBC is a 100%
risk exposure to HSBC whereas £2m invested in a MMF may end up with say £10,000
being invested with HSBC through the MMF.  For authorities particularly concerned
with risk exposure to banks, MMFs offer an effective way of minimising risk exposure
while still getting much better rates of return than available through the DMADF. 
c. Ultra Short Dated Bond Funds .  These funds are similar to MMFs, can still be AAA
rated but have Variable Net Asset Values (VNAV) as opposed to a traditional MMF
which has a Constant Net Asset Value (CNAV). They aim to achieve a higher yield and
to do this either take more credit risk or invest out for longer periods of time, which
means they are more volatile. These funds can have WAM’s and Weighted Average
Life (WAL’s) of 90 – 365 days or even longer. Their primary objective is yield and capital
preservation is second.  They therefore are a higher risk than MMFs and
correspondingly have the potential to earn higher returns than MMFs. 
d. Gilt funds.  These are funds which invest only in U.K. Government gilts.  They offer a
lower rate of return than bond funds but are highly rated both as a fund and through
investing only in highly rated government securities.  They offer a higher rate of return
than investing in the DMADF but they do have an exposure to movements in market
prices of assets held. 
e. Bond funds.  These can invest in both government and corporate bonds.  This
therefore entails a higher level of risk exposure than gilt funds and the aim is to achieve
a higher rate of return than normally available from gilt funds by trading in non-
government bonds.    
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4.  SECURITIES ISSUED OR GUARANTEED BY GOVERNMENTS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it matures or is sold.  The annual
earnings on a security is called a yield i.e. it is normally the interest paid by the issuer divided
by the price you paid to purchase the security unless a security is initially issued at a
discount e.g. treasury bills..   
a. Treasury bills.  These are short term bills (up to 12 months, although none have
ever been issued for this maturity) issued by the Government and so are backed
by the sovereign rating of the UK.  The yield is higher than the rate of interest paid
by the DMADF and another advantage compared to a time deposit in the DMADF
is that they can be sold if there is a need for access to cash at any point in time. 
However, there is a spread between purchase and sale prices so early sales could
incur a net cost during the period of ownership. 
b. Gilts.  These are longer term debt issuance by the UK Government and are backed by
the sovereign rating of the UK. The yield is higher than the rate of interest paid by the
DMADF and another advantage compared to a time deposit in the DMADF is that they
can be sold if there is a need for access to cash at any point in time.  However, there is
a spread between purchase and sale prices so early sales may incur a net cost. Market
movements that occur between purchase and sale may also have an adverse impact
on proceeds. The advantage over Treasury bills is that they generally offer higher yields
the longer it is to maturity (for most periods) if the yield curve is positive. 
c. Bond issuance issued by a financial institution which is explicitly guaranteed by
the UK Government e.g. National Rail.  This is similar to a gilt due to the explicit
Government guarantee. 
d. Sovereign bond issues (other than the UK govt) denominated in Sterling.  As for
gilts but issued by other nations.  Use limited to issues of nations with at least the same
sovereign rating as for the UK. 
e. Bonds issued by Multi Lateral Development Banks (MLDBs).  These are similar to
c. and e. above but are issued by MLDBs which are typically guaranteed by a group of
sovereign states e.g. European Bank for Reconstruction and Development.
5.  SECURITIES ISSUED BY CORPORATE ORGANISATIONS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it is sold.  The annual earnings on
a security is called a yield i.e. is the interest paid by the issuer divided by the price you paid
to purchase the security.  These are similar to the previous category but corporate
organisations can have a wide variety of credit worthiness so it is essential for local
authorities to only select the organisations with the highest levels of credit worthiness. 
Corporate securities are generally a higher risk than government debt issuance and so earn
higher yields. 
a. Certificates of deposit (CDs).  These are shorter term securities issued by deposit
taking institutions (mainly financial institutions). They are negotiable instruments, so can
be sold ahead of maturity and also purchased after they have been issued.  However,
that liquidity can come at a price, where the yield could be marginally less than placing
a deposit with the same bank as the issuing bank. 
b. Commercial paper.  This is similar to CDs but is issued by commercial
organisations or other entities.  Maturity periods are up to 365 days but commonly
90 days.  
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c. Corporate bonds.  These are (long term) bonds (usually bearing a fixed rate of
interest) issued by a financial institution, company or other non-government issuer
in order to raise capital for the institution as an alternative to issuing shares or
borrowing from banks.  They are generally seen to be of a lower creditworthiness
than government issued debt and so usually offer higher rates of yield. 
d. Floating rate notes.  These are bonds on which the rate of interest is established
periodically with reference to short-term interest rates.  
6.  OTHER
a. Local Authority Mortgage Scheme.  Authorities who are participating in the Local
Authority Mortgage Guarantee Scheme (LAMS) may be required to place a deposit
with the mortgage provider(s) up to the full value of the guarantee.  The deposit will
be in place for the term of the guarantee i.e. 5 years (with the possibility of a further
2 year extension if the account is 90+ days in arrears at the end of the initial 5
years) - and may have conditions / structures attached.  The mortgage provider will
not hold a legal charge over the deposit.
b. Loans to third parties – This would involve the Council borrowing from the
PWLB/markets and onward lending to Registered Social Landlords to enable them
to access lower cost loans and kickstart developments of affordable mid-market
homes.  The risk associated with such an investment would be mitigated by an
assessment of the counterparty in advance of any loan being granted and through
the application of a premium on the loan rate.  Interest would be paid by the RSL
over the term of the loan, with repayment of principal upon the earlier of 10/20
years or at the point of house sales.  The Council will also request that a standard
security is taken over the property which would allow the Council to require the sale
of the homes to another landlord, providing greater risk mitigation.
c. Subordinated Debt Subscription to the SPV set up to deliver the Newbattle
Centre project – this involved the Council subscribing £332,806 of subordinated
debt to the SPV that was set up to deliver the Newbattle Centre project (2 year
construction and 25 year operational contract length). The length of the investment
is 25 years with the subscription made at operation commencement of the contract. 
The repayment profile will comprise 81% of the principal remaining invested until
the final two years of the contract. The risk associated with this type of investment
will be mitigated through an annual assessment as a minimum to review the holding
of such debt, and whether the exposure to risk arising from the investment has
changed over the period.
d. ESCO: Midlothian Energy Limited (MEL) Joint Venture between Midlothian Council
and Vattenfall to deliver energy supply to Shawfair using heat supplied from the
Millerhill Energy from Waste plant and related projects.
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Table 1: Permitted Investments 
1.1  Deposits
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Max
Transaction
Value
Debt Management Agency
Deposit Facility
UK
Government Term No 100% 6 months n/a
Term deposits – local authorities Quasi-UK
Government Term No 100% 5 years £15m
Call accounts – banks and
building societies
Green  Instant No 100% 1 day £15m
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.2 Deposits with counterparties currently in receipt of government support / ownership
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day £30m
UK  nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 2 years £30m
UK  nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 2 years £30m
Non-UK (high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day £15m
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
If forward deposits are made, the forward period plus the deal period equate to the maximum
maturity period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies
(OEICs) 
Investment Category Minimum
Credit Criteria  Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
Government Liquidity Funds AAA Instant No 100% 1 day £15m
Money Market Funds CNAV AAA Instant No 100% 1 day £15m
Money Market Funds LVNAV AAA Instant No 100% 1 day £15m
Money Market Funds VNAV AAA Instant No 100% 1 day £15m
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week £15m
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week £15m
Bond Funds AAA T+2 or
longer Yes 50% 2 days £15m
Gilt Funds AAA T+2 or
longer Yes 50% 2 days £15m 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 6 months
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Max
Transaction
Value
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+1 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 20 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
ESCO n/a Term No £10.2m n/a 
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5.8 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 
Midlothian Council Permitted Investments, Associated Controls and Limits
Type of Investment Treasury Risks Mitigating Controls Council
Limits
Cash type instruments
a. Deposits with the Debt
Management Account
Facility (UK
Government) (Very
low risk)
This is a deposit with the UK Government and as
such counterparty and liquidity risk is very low, and
there is no risk to value.  Deposits can be between
overnight and 6 months.
Little mitigating controls required.  As
this is a UK Government investment the
monetary limit is unlimited to allow for a
safe haven for investments.
As shown in
Appendix 5.2.
b. Deposits with other
local authorities or
public bodies (Very
low risk)
These are considered quasi UK Government debt
and as such counterparty risk is very low, and there
is no risk to value.  Deposits can only be broken with
the agreement of the counterparty, and penalties can
apply.
Deposits with other non-local authority bodies will be
restricted to the overall credit rating criteria.
Little mitigating controls required for
local authority deposits, as this is a
quasi UK Government investment.
Non- local authority deposits will follow
the approved credit rating criteria.
As shown in
Appendix 5.2.
c. CNAV, LVNAV and
VNAV Money Market
Funds (MMFs) (Low to
very low risk)
Pooled cash investment vehicle which provides very
low counterparty, liquidity and market risk.  These
will primarily be used as liquidity instruments.
Funds will only be used where the MMF
has a “AAA” rated status from either
Fitch, Moody’s or Standard & Poors.
As shown in
Appendix 5.2.
d. Ultra Short Dated Bond
Funds (low risk)
Pooled cash investment vehicle which provides very
low counterparty, liquidity and market risk.  These
will primarily be used as liquidity instruments.
Funds will only be used where the Ultra
Short Dated Bond Fund has a “AAA”
rated status from either Fitch, Moody’s
or Standard and Poor’s.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
e. Call account deposit
accounts with financial
institutions (banks and
building societies)
(Low risk depending
on credit rating)
These tend to be low risk investments, but will
exhibit higher risks than categories (a), (b) and (c)
above.  Whilst there is no risk to value with these
types of investments, liquidity is high and
investments can be returned at short notice.
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by
MUFG Corporate Markets overlaid.
On day to day investment dealing with
this criteria will be further strengthened
by the use of additional market
intelligence.
As shown in
Appendix 5.2.
f. Term deposits with
financial institutions
(banks and building
societies) (Low to
medium risk
depending on period
& credit rating)
These tend to be low risk investments, but will
exhibit higher risks than categories (a), (b), (c) and
(d) above.  Whilst there is no risk to value with these
types of investments, liquidity is low and term
deposits can only be broken with the agreement of
the counterparty, and penalties may apply.  
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by
MUFG Corporate Markets overlaid.
On day to day investment dealing, this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
g. Government Gilts and
Treasury Bills (Very low
risk)
These are marketable securities issued by the
UK Government and as such counterparty and
liquidity risk is very low, although there is
potential risk to value arising from an adverse
movement in interest rates (no loss if these
are held to maturity.
Little counterparty mitigating controls are
required, as this is a UK Government
investment.   The potential for capital loss will
be reduced by limiting the maximum
monetary and time exposures
As shown in
Appendix 5.2.
h. Certificates of deposits with
financial institutions (Low
risk)
These are short dated marketable securities
issued by financial institutions and as such
counterparty risk is low, but will exhibit higher
risks than categories (a), (b) and (c) above. 
There is risk to value of capital loss arising
from selling ahead of maturity if combined with
an adverse movement in interest rates (no
loss if these are held to maturity).  Liquidity
risk will normally be low.
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s.  The selection defaults to the lowest
available colour band / credit rating to provide
additional risk control measures.
Day to day investment dealing with this
criteria will be further strengthened by the use
of additional market intelligence.
As shown in
Appendix 5.2.
i. Structured deposit facilities
with banks and building
societies (escalating rates,
de-escalating rates etc.)
(Low to medium risk
depending on period &
credit rating)
These tend to be medium to low risk
investments, but will exhibit higher risks than
categories (a), (b), (c) and (d) above.  Whilst
there is no risk to value with these types of
investments, liquidity is very low and
investments can only be broken with the
agreement of the counterparty (penalties may
apply).  
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s, with the credit scoring methodology
by MUFG Corporate Markets overlaid.
On day to day investment dealing, this criteria
will be further strengthened by the use of
additional market intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
j. Corporate bonds (Medium to
high risk depending on
period & credit rating)
These are marketable securities issued by
financial and corporate institutions.
Counterparty risk will vary and there is risk to
value of capital loss arising from selling ahead
of maturity if combined with an adverse
movement in interest rates.  Liquidity risk will
be low.
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s.  The
selection defaults to the lowest
available colour band / credit rating to
provide additional risk control
measures.  Corporate bonds will be
restricted to those meeting the base
criteria.
Day to day investment dealing with this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Other types of investments
k. Loans to third parties Using the example of a loan to a RSL, these
would be medium risk investments, exhibiting
higher risks than categories (a)-(f) above. 
They are also highly illiquid and are only repaid
at the end of a defined period of time (up to 20
years) or on the sale of a property, whichever is
the earlier.
The risk associated with such an
investment would be mitigated through
the application of a premium on the
loan rate.  The Council will also request
that a standard security is taken over
the property which would allow the
Council to require the sale of the homes
to another landlord, providing greater
risk mitigation.
£25m
l. Non-local authority
shareholdings
These are non-service investments which may
exhibit market risk, be only considered for
longer term investments and will be likely to be
liquid.
Any non-service equity investment will
require separate Member approval and
each application will be supported by
the service rational behind the
investment and the likelihood of loss.
Per Existing
m. Local Authority Mortgage
Scheme (LAMS)
These are service investments at market rates
of interest plus a premium. 
As shown in
Appendix 5.2.
n. Subordinated Debt Subscription
to Newbattle Centre SPV
These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council and Scottish Government
(via the SFT) are participants in and
party to the governance and controls
within the project structure. As such
they are well placed to influence and
ensure the successful completion of the
project’s term.
As shown in
Appendix 5.2.
o. ESCO These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council is in a joint venture
partnership and therefore party to the
governance and controls within the
project structure. As such the Council is
As shown in
Appendix 5.2.
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46
well placed to influence and ensure the
successful completion of the project’s
term 
The Monitoring of Deposit Counterparties - The status of counterparties will be monitored regularly.  The Council receives credit rating and
market information from MUFG Corporate Markets, including when ratings change, and counterparties are checked promptly.  On occasion
ratings may be downgraded when an investment has already been made.  The criteria used are such that a minor downgrading should not
affect the full receipt of the principal and interest.  Any counterparty failing to meet the criteria will be removed from the list immediately by the
Chief Financial Officer & Section 95 Officer, and if required new counterparties which meet the criteria will be added to the list. 
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5.9 APPENDIX: Approved countries for investments 
Based on the lowest available rating as at 30.01.2026 
AAA
• Australia
• Denmark
• Germany
• Netherlands
• Norway
• Singapore
• Sweden
• Switzerland 
AA+
• Canada
• U.S.A. 
AA
• Abu Dhabi (UAE)
• Finland 
AA-
• U.K. 
A+
• Belgium
• France 
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48
5.10 APPENDIX: Treasury management scheme of delegation
(i) Full Council
• receiving and reviewing reports on treasury management policies, practices and
activities;
• approval of annual strategy.
• approval of/amendments to the organisation’s adopted clauses, treasury
management policy statement and treasury management practices;
• budget consideration and approval;
• approval of the division of responsibilities;
• receiving and reviewing regular monitoring reports and acting on
recommendations;
• approving the selection of external service providers and agreeing terms of
appointment. 
(iii) Audit Committee
• reviewing treasury management reports, the treasury management policy and
procedures, and making recommendations to the responsible body. 
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49
5.11 APPENDIX: The treasury management role of the section 95 officer
The S95 (responsible) officer
• recommending clauses, treasury management policy/practices for approval,
reviewing the same regularly, and monitoring compliance;
• submitting regular treasury management policy reports;
• submitting budgets and budget variations;
• receiving and reviewing management information reports;
• reviewing the performance of the treasury management function;
• ensuring the adequacy of treasury management resources and skills, and the
effective division of responsibilities within the treasury management function;
• ensuring the adequacy of internal audit, and liaising with external audit;
• recommending the appointment of external service providers;
• preparation of a capital strategy to include capital expenditure, capital financing,
non-financial investments and treasury management, with a long term timeframe;
• ensuring that the capital strategy is prudent, sustainable, affordable and prudent in
the long term and provides value for money;
• ensuring that due diligence has been carried out on all treasury and non-financial
investments and is in accordance with the risk appetite of the authority;
• ensure that the authority has appropriate legal powers to undertake expenditure
on non-financial assets and their financing;
• ensuring the proportionality of all investments so that the authority does not
undertake a level of investing which exposes the authority to an excessive level of
risk compared to its financial resources;
• ensuring that an adequate governance process is in place for the approval,
monitoring and ongoing risk management of all non-financial investments and
long term liabilities;
• provision to members of a schedule of all non-treasury investments including
material investments in subsidiaries, joint ventures, loans and financial guarantees
ensuring that members are adequately informed and understand the risk
exposures taken on by an authority;
• ensuring that the authority has adequate expertise, either in house or externally
provided, to carry out the above;
• creation of Treasury Management Practices which specifically deal with how non-
treasury investments will be carried out and managed, to include the following:-
o Risk management (TMP1 and schedules), including investment and risk
management criteria for any material non-treasury investment portfolios;
o Performance measurement and management (TMP2 and schedules),
including methodology and criteria for assessing the performance and
success of non-treasury investments;
o Decision making, governance and organisation (TMP5 and schedules),
including a statement of the governance requirements for decision making
in relation to non-treasury investments; and arrangements to ensure that
appropriate professional due diligence is carried out to support decision
making;
o Reporting and management information (TMP6 and schedules), including
where and how often monitoring reports are taken;
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50
o Training and qualifications (TMP10 and schedules), including how the
relevant knowledge and skills in relation to non-treasury investments will
be arranged.
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Audit Committee
Monday 23 February 2026
Item No 5.4 
Internal Audit Work to January 2026 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is asked to:
a) Consider the Executive Summary of the final Internal Audit assurance report issued
associated with the delivery of the approved Internal Audit Annual Plan 2025/26;
b) Note the Internal Audit Consultancy and Other Work carried out in accordance with the
approved Internal audit Charter; and
c) Acknowledge the assurance provided on internal controls and governance arrangements
in place for the areas covered by this Internal Audit work. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide members of the Audit Committee with details of the
recent work carried out by Internal Audit and the findings and recommended audit actions
agreed by Management to improve internal controls and governance arrangements. 
The Internal Audit Annual Plan 2025/26 was approved by the Audit Committee on 24
February 2025. Internal Audit has carried out work associated with the delivery of the plan to
meet its objective of providing an opinion on the efficacy of the Council’s risk management,
internal control and governance. 
An Executive Summary of the final Internal Audit assurance report issued, including audit
objective, findings, good practice and recommendations (where appropriate), and the Chief
Internal Auditor’s independent and objective opinion on the adequacy of the control
environment and governance arrangements within each audit area is shown in Appendix 1. 
The Internal Audit function conforms to the professional standards as set out in Global
Internal Audit Standards (GIAS) including the production of this report to communicate the
results of the reviews. 
Date 11 February 2026 
Report Contact:
Duncan Stainbank
duncan.stainbank@midlothian.gov.uk 
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3 Progress Report 
3.1 The Internal Audit Annual Plan 2025/26 was approved by the Audit Committee on 24
February 2025. Internal Audit has completed the following work in the period from 14
November 2025 to 31 January 2026 associated with the delivery of the plan to meet its
objective of providing an opinion on the efficacy of the Council’s risk management, internal
control and governance. 
3.2 The Internal Audit function conforms to the professional standards as set out in Global
Internal Audit Standards (GIAS), including the production of this report to communicate the
results. 
3.3 Internal Audit issued a final assurance report on the following subject:
• Direct Payments Self Directed Support. 
3.4 An Executive Summary of the final Internal Audit assurance report issued including audit
objective conclusions, key findings, recommendations, areas of good practice, the Chief
Internal Auditor’s independent and objective opinion on the adequacy of the control
environment and governance arrangements within each audit area is shown in Appendix 1. 
3.5 The Direct Payments Self Directed Support review has been overall categorised as
Reasonable Assurance. The definitions for Internal Audit assurance categories are as
follows: 
Level Definition
Substantial
Assurance
A sound system of governance, risk management and control exists, with internal controls
operating effectively and being consistently applied to support the achievement of objectives in
the area audited. 
Reasonable
Assurance
There is a generally sound system of governance, risk management and control in place. Some
issues, non-compliance or scope for improvement were identified which may put at risk the
achievement of objectives in the area audited. 
Limited
Assurance
Significant gaps, weaknesses or non-compliance were identified. Improvement is required to the
system of governance, risk management and control to effectively manage risks to the
achievement of objectives in the area audited. 
No Assurance Immediate action is required to address fundamental gaps, weaknesses or non-compliance
identified. The system of governance, risk management and control is inadequate to effectively
manage risks to the achievement of objectives in the area audited. 
Internal Audit Consultancy and Other Work 
3.11 Internal Audit staff have been involved in the following for the Council to meet its aims and
objectives, and its roles and responsibilities in accordance with the approved Internal Audit
Charter and Strategy:
a) Completed work to verify the reported figures in the Lock Up Garage Asset Review. 
b) In its critical friend role provided an independent view and challenge at various forums
including: Capital Plan and Asset Management Board, Chief Officers Risk & Resilience
Group, and the Integrity Group.
c) Learning and development during the research stage of new audit areas for all Internal
Audit team members and through joining audit forums (Computer Audit Sub-group) and
meetings; and
d) Monitored publication of Audit Scotland reports. 
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Recommendations 
3.12 Recommendations in reports are suggested changes to existing procedures or processes to
improve the controls or to introduce controls where none exist. The grading of each
recommendation reflects the risk assessment of non-implementation, being the product of the
likelihood of the risk materialising and its impact: 
High Recommendations relating to factors fundamental to the success of the control objectives of the
system. The weaknesses may give rise to significant financial loss/misstatement or failure of
business processes. 
Medium Recommendations which will improve the efficiency and effectiveness of the existing controls. 
Low Recommendations concerning minor issues that are not critical, but which may prevent attainment
of best practice and/or operational efficiency. 
Outwith the report, Internal Audit informs operational managers about other matters as part of continuous
improvement. 
3.8 The table below summarises the number of Internal Audit recommendations made during
2025/26:
Recs Rating 2025/26 Number of Recs
High 1
Medium 6
Low 7
Not Graded 0
Sub-total reported this period 13
Previously reported 60
Total 73 
Recommendations agreed with action plan 73
Not agreed; risk accepted 0
Total 73 
4 Report Implications (Resource, Digital, Risk and Equalities) 
4.1 Resource 
Resource implications of implementing Internal Audit recommendations are considered as
part of the audit process to ensure these are reasonable and proportionate to the risks. 
4.2 Digital 
There are no digital implications arising from this report. 
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4.3 Risk 
The GIAS require Internal Audit to evaluate the effectiveness of the Council’s Risk
Management arrangements and contribute to improvements in the process. At the start of
each audit engagement, to capture potential areas of risk and uncertainty more fully, key
stakeholders have been consulted and risk registers have been considered. During each
audit engagement the management of risk has been tested. 
It is anticipated that improvements in the management and mitigation of risks will arise as a
direct result of Management implementing the Internal Audit recommendations made. If audit
recommendations are not implemented, there is a greater risk of financial loss and/or
reduced operational efficiency and effectiveness, and Management may not be able to
demonstrate improvement in internal control and governance arrangements, and effective
management of risks. 
4.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget change, which
affects people (the public or staff), so an Integrated Impact Assessment (IIA) is not an
applicable consideration. 
The Internal Audit work is carried out in accordance with the appropriate legislation and
professional standards. The latter includes compliance by those within the Internal Audit
function with the ethical requirements set out in the GIAS which is appropriate for the
profession of Internal Audit founded as it is on trust placed in its independent and objective
assurance about risk management, internal control and governance. 
4.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within the Single Midlothian
Plan to which Midlothian Council and its Community Planning Partners have made a
commitment (Reducing the gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the impact of climate
change), good governance is important to enable Midlothian Council to deliver its key
priorities in support of achieving the Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow supported by the 9 drivers
for change. Implementing the 9 drivers for change in practice is applicable to the Council’s
Internal Audit service provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
Implementation by Management of the actions associated with Internal Audit
recommendations, that are designed to improve internal control and governance
arrangements and management of risks, underpins the Council’s own continuous
improvement arrangements to enhance its effectiveness, thus supporting the delivery of the
Council’s best value duties. 
A.5 Involving Communities and Other Stakeholders 
The Chief Internal Auditor is accountable to the Audit Committee which, in fulfilling its
governance role, acts as a bridge between the Council and other stakeholders. 
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This report has been presented to Senior Management relevant to the areas audited and
have agreed the final Internal Audit assurance reports as set out in the relevant Executive
Summary within Appendix 1. 
A.6 Impact on Performance and Outcomes 
The Findings and Recommendations from Internal Audit work during the year are designed to
assist the Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
Internal Audit assurance work includes assessments on when a preventative approach can
be adopted. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable development. Good governance
is important to enable Midlothian Council to achieve its objectives. 
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Appendix 1: Executive Summary: Direct Payments – Self Directed Support (SDS) 
Conclusion: Reasonable Assurance
Policies and procedures are in place for Direct Payments Self Directed Support (SDS) and guidance is being updated within Adult Health and
Social Care. Strength-based assessments have been undertaken and authorisation processes are in place to ensure that Direct Payments
are only made for assessed needs and in accordance with an appropriately completed financial assessment. Testing highlighted that Direct
Payment Agreements and Local Authority Agreements to Employ a Family Member forms were not on file and Direct Payment care packages
were not reviewed on a timely basis. Financial reassessments were not undertaken on a timely basis and financial outcome letters were not
sent to service users whose contributions had changed following reassessment. A number of cases were identified where the service user
had not received a Direct Payment for a period of time which may be due to the service user not adequately managing their personal budget. 
Background 
Under the Social Care (Self-Directed Support) Scotland Act 2013, Self-Directed Support (SDS) options must be offered to all social work service
users which include four options: Direct Payment of funds to service users to purchase their own care, service user direction over the use of funds
held by a third party, Council selection of and payment for services, or a mix of all three. Direct Payments are local health and social care payments
for people with an assessed need who would prefer to arrange and pay for their own care and support.  Information is recorded on the case
management system, Mosaic and Direct Payments are made through a BACS transfer paid into the service user’s bank account. The Council is
currently considering introducing pre-paid cards for service users. 
Summary of findings & recommendations
• Direct Payment agreements formally detailing how the funding will be used and the Local Authority Agreement to Employ a Family Member
form were not on file for any of the cases tested. Management will ensure the agreements and forms are completed and held on file by 30
September 2026.
• Financial reassessment reviews were not undertaken on a timely basis and financial outcome letters were not issued to service users
whose contributions had changed following a financial re-assessment for the cases tested. Management will ensure financial reviews are
completed and letters issued by 31 March 2026.
• A number of cases were identified where a Direct Payment had not been issued for a period of time. Management have agreed to
investigate these cases and establish if any further action is required by 30 September 2026.
• Testing highlighted that Direct Payment care package reviews had not always been undertaken when required.  There is no regular specific
reporting of Direct Payment cases that are due for review. A report on Direct Payment cases due for review will be regularly produced by 30
September 2026 and the completion of reviews managed in accordance with the resources and pressures of the whole service.   
Recommendation Summary
Recommendations
Grade 
High Medium Low Total
Current Report - 6  7 13
Prior Report  N/A N/A N/A N/A
Materiality 
314 people were in receipt of Direct Payments (as at August
2025) and the total value of Direct Payments was £1,262,940
(from April to September 2025). The total value of Direct
Payments during 2024/25 was £2,610,325.
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Headlines
Objectives Conclusion Comments
1. Policies and procedures
for Self-Directed Support
and Direct Payments are in
place which comply with
legislation and includes local
eligibility criteria
Reasonable
Assurance 
Policies and procedures are in place for SDS which includes Direct Payments and these are in
line with best practice, relevant regulations and legislation.  The Council offers all SDS options
which are discussed as part of the strength-based assessment.  Adult Health and Social Care
are in the process of updating the Direct Payments guidance and the update will incorporate the
recommendations made within this audit report.   
There is a lack of Direct Payment operating procedures detailing responsibilities for tasks within
each service area which has led to processes not being completed due to a misunderstanding
over who is responsible for what. 
The SDS policy states that reviews should be undertaken in line with the Council’s review policy
but the review policy hasn’t been updated since 2011 and there is no review policy on the Internet.  
The Council’s 2025/26 charging policy was applicable from 1 April 2025 but was not published
on the website and intranet until December 2025. 
2. Strength-based
assessments have been
undertaken, and
authorisation processes are
in place to ensure that
Direct Payments are only
made for assessed needs
and in accordance with an
appropriately completed
financial assessment.
Reasonable
Assurance 
Strength-based assessments are undertaken (for Adult Services and Children’s Services) and
proposed support packages are submitted to the Resource Panel for authorisation. It was
noted that Adult Health and Social Care used different assessment forms which did not always
detail service users outcomes. Direct Payment guidance is currently being updated to ensure
there is a consistent practice within Adult Health and Social Care. 
If a client chooses Direct Payment Option 1, part of the assessment involves the practitioner or
the social worker discussing the practicalities of the Direct Payment process such as who is
managing the Direct Payment and service users are made aware of the support available
however this is not formally recorded on the Mosaic form as part of the assessment.   Within
the SDS Act 2014, there are provisions for support to be provided by family members under
Direct Payments provided the conditions are appropriate.  If a user requests for a family
member to provide the services of a Personal Assistant (PA), this must be documented on the
Direct Payment Agreement and a Local Authority Agreement to Employ a Family Member form
should be completed.  This is then assessed to determine if the arrangement is suitable    
From the 15 cases reviewed, 2 cases had a family member employed as a PA but no form had
been completed.   
Financial assessments are completed in accordance with the relevant legislation and guidance. 
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3. Adequate financial
controls and monitoring
procedures are in place and
regular reviews are
undertaken to ensure Direct
Payments are used
appropriately and only for
eligible support.
Limited
Assurance 
Direct Payment audit monitoring returns must be completed by service users every quarter to
demonstrate that funds provided have been spent appropriately.  Checks are undertaken within
the Operational Support team and cases are referred to the service manager if inappropriate
spend is identified.  If sufficient evidence is not received the next payment is withheld. 
Reminders are sent out every quarter, but this is not always followed up if no evidence is
received.  It was noted that there are a number of Direct Payment client accounts which have
not been paid for a period of time which may be due to the service user not adequately
managing their personal budget. 
Financial reassessments should be undertaken annually to establish whether the service user
is required to make a financial contribution.  These are not being completed on a timely basis
and Financial Assessment Outcome Letters had not been issued for the cases tested following
reassessment which required a change to their contribution. There were 475 cases due for
reassessment (Nov25) and only 205 had been undertaken (this includes non Direct Payment
cases). 
Audit testing identified 2 cases where small overpayments were paid by the service users due
to them not being informed of their updated contributions after reassessment. 
The Care and Support (Direct Payments) Regulations 2014 set out that the local authority
must review Direct Payments initially within 6 months, and thereafter every 12 months
This process is managed in accordance with the reviews of all other social work client groups 
It was noted from the sample testing of 15 cases that 11 reviews scheduled on Mosaic had
gone past their review date.  A report was requested to identify how many care package
reviews in relation to Direct Payments have gone past their review date but this information
could not be provided at the time of testing.  
4. Service users are
receiving appropriate
information, support and
guidance in managing their
Direct Payments and
appropriate action is taken
to recover any funds that
have not been utilised or not
utilised for appropriate
purposes.
Limited
Assurance 
A Direct Payment Agreement formally detailing the terms and conditions, the agreed budget
and, how it will be used to meet the identified outcomes and needs of the supported person
was not on file for any of the 15 cases sampled.  This can result in confusion and disputes over
what the funding can be used for. 
The Council commissions LCIL to support service users who receive a Direct Payment. The
support offered from LCIL includes payroll services, helping with money management and
maintaining accurate records.  A Statement of Rates letter is in place for 2025-26 which details
the cost of the service for approximately 95 individuals (circa £20k pa) and that periodic service
reviews shall be carried out by the Council and the provider to ensure effective delivery of the
service.  Testing highlighted a case where LCIL were not sending paperwork to the Operational
Support team on a timely basis to enable the quarterly audit checks to be undertaken.  
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Areas where expected controls are met/good practice 
No. Areas of Positive Assurance
1. Policies and procedures are in place for Self-Directed Support (SDS) which includes Direct Payments as one of the options and
includes the eligibility criteria.  These are in line with best practice, relevant regulations and legislation.  Information is available on the
Council’s website about Self Directed Support including Direct Payments as one of the options which includes information on managing
funds. 
2. The Council has a ‘charging policy’ for residential and non-residential services which complies with COSLA’s National Strategy and
Guidance for Charges Applying to Non-Residential Social Care Services, the National Assistance Act 1948 and the National Assistance
(Assessment of Resources) Regulations 1992.
3. Strength based assessments are carried out for all service users (adults services and children services) considering the self-directed
support route which involves the client and establishes desired outcomes.  All care packages are agreed at the resource panel
(separate resource panels for adults and children) and confirms that as part of the assessment undertaken, the eligible person has
been offered each of the 4 options. 
An outcome assessment forum was established within Children’s Services in March 2025 to review the assessments before they go to
the resource panel. This also provides a training opportunity for social workers. Children Services use a consistent assessment form
and a budget calculator which is currently being reviewed. 
4. Service users in receipt of a Direct Payment are required to provide audit monitoring returns every quarter to demonstrate that funds
provided have been spent appropriately.  No further payments are made if evidence is not submitted and payments are not topped up if
the service user has sufficient funds.  The service reviews the evidence to determine whether support has been purchased in accordance
with the agreed care package.  If it is identified that payments have not been used in accordance with the relevant care package,
arrangements are made to reclaim the monies.
5 A disability team was established in September 2024 in Children’s Services. The service is improving practice and consistency to ensure
families are receiving a fair and equitable response to assessed social work needs. The development of this team supports the Business
Transformation Project focused on improving transitions across Education, Children’s Services and Adult Services. The introduction of
the team will support better tracking of young people who need support as they move into adulthood.
6 A process is in place to terminate Direct Payments for service users who have passed away and to raise an invoice for any outstanding
monies. 
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Recommendation Grading/Overall Opinion Definitions
Recommendation Definition
High Recommendations relating to factors fundamental to the success of the control objectives of the system. The
weaknesses may give rise to significant financial loss/misstatement or failure of business processes.
Medium Recommendations which will improve the efficiency and effectiveness of the existing controls.
Low Recommendations concerning minor issues that are not critical, but which may prevent attainment of best practice
and/or operational efficiency.
Levels of Assurance Definition 
Substantial Assurance A sound system of governance, risk management and control exists, with internal controls operating effectively and
being consistently applied to support the achievement of objectives in the area audited.
Reasonable Assurance There is a generally sound system of governance, risk management and control in place. Some issues, noncompliance
or scope for improvement were identified which may put at risk the achievement of objectives in the area audited.
Limited Assurance
Significant gaps, weaknesses or non-compliance were identified. Improvement is required to the system of
governance, risk management and control to effectively manage risks to the achievement of objectives in the area
audited.
No Assurance
Immediate action is required to address fundamental gaps, weaknesses or non-compliance identified. The system
of governance, risk management and control is inadequate to effectively manage risks to the achievement of
objectives in the area audited. 
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Audit Committee
Monday 23 February 2026
Item No 5.5 
Internal Audit Strategy and Annual Plan 2026/27 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Note the changes to the Internal Audit Strategy outlined in section 4
of this report; 
b) Note the outline of the Internal Audit planning process outlined in
section 5 of this report;
c) Approve the Internal Audit Strategy (Appendix 1); and  
d) Approve the Internal Audit Annual Plan 2026/27 (Appendix 2). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
to the proposed Internal Audit Strategy and Annual Plan 2026/27 to
enable the Chief Internal Auditor to prepare annual opinions on the
adequacy of the overall control environment for Midlothian Council, and
Midlothian Integration Joint Board (MIJB). 
The Internal Audit Strategy at Appendix 1 outlines the strategic
direction for how Internal Audit will achieve its objectives, which are set
out in the Internal Audit Charter, in conformance with Global Internal
Audit Standards. It guides the Internal Audit function in delivering high
quality internal audit services to Midlothian Council and the MIJB. 
The Internal Audit Annual Plan 2026/27 at Appendix 2 has been
developed by the shared Chief Internal Auditor and the Principal
Internal Auditor. It sets out the proposed range and breadth of audit
activity within the audit programme of work to enable the Chief Internal
Auditor to prepare the independent and objective audit opinions for
Midlothian Council and the MIJB. A separate Internal Audit Annual Plan
2026/27 for the MIJB will be presented to its Audit and Risk Committee.
Key components of the audit planning process include a clear
understanding of each organisation’s functions, associated risks, and
assurance framework. 
Date 11 February 2026 
Report Contacts
Duncan Stainbank, Chief Internal Auditor 
duncan.stainbank@midlothian.gov.uk     
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3 Background 
3.1 The Local Authority Accounts (Scotland) Regulations 2014 require a
local authority to operate a professional and objective internal auditing
service. This service must be provided in accordance with recognised
standards and practices in relation to internal auditing. Recognised
standards and practices are those set out in the Global Internal Audit
Standards (GIAS) as adjusted by the UK Public Sector Application
note. 
3.2 The Midlothian Council Internal Audit function is following the
professional standards as set out in the Global Internal Audit Standards
(GIAS) as adjusted by the UK Public Sector Application note, from the
1 April 2025, where resources allow. In accordance with GIAS to
develop an effective internal audit strategy and plan, the chief audit
executive must understand the organization’s governance, risk
management, and control processes. 
3.3 GIAS also requires that the chief audit executive must develop and
implement a strategy for the internal audit function that supports the
strategic objectives and success of the organization and aligns with the
expectations of the board (the Audit Committee acting on behalf of the
Council), senior management, and other key stakeholders, including
Audit Scotland and the Midlothian Public. 
3.4 Internal Audit resources and services are also provided by Midlothian
Council’s Internal Audit team to the Midlothian Health and Social Care
Integration Joint Board (MIJB), including the appointed MIJB Chief
Internal Auditor. The Internal Audit Charter and Strategy are applicable
to each organisation. 
4        Internal Audit Strategy 
4.1 GIAS Standard 9.2 Internal Audit Strategy states, that; “the chief audit
executive must develop and implement a strategy for the internal audit
function that supports the strategic objectives and success of the
organization and aligns with the expectations of the board, senior
management, and other key stakeholders.” 
4.2 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Strategy at Appendix 1. It outlines the
strategic direction for how Internal Audit will achieve its objectives,
which are set out in the Internal Audit Charter, in conformance with
GIAS. It guides the Internal Audit function in delivering high quality
internal audit services to Midlothian Council and the Midlothian Health
and Social Care Integration Joint Board (MIJB). 
4.4 The Internal Audit Strategy:
• Outlines the assurance framework, providing clarity of the
respective responsibilities of Management for designing and
monitoring governance and control systems and of the role of
Internal Audit in providing independent assurance thereon;
• States how the key themes which are integral to the assurance
gathering process across the organisation’s activities will be
covered to inform the annual Internal Audit opinion statement;
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• Provides focused supporting initiatives to develop continuous
improvement in the completion of Internal Audit. 
• Describes the approach to the development of the risk based
Internal Audit annual plan;
• Sets out the relative allocation of Internal Audit resources;
• Outlines how the Internal Audit programme of work will be
delivered to add value; and
• Describes the monitoring and reporting of Internal Audit findings
from its work and progress with its plans to the relevant
organisation’s audit committee/board. 
5        Internal Audit Annual Plan 2026/27 
5.1 The key standards within the GIAS relating to the Internal Audit Plan is
Standard 9.4 Internal Audit Plan, which states the following:  The chief
audit executive must create an internal audit plan that supports the
achievement of the organization’s objectives. The chief audit executive
must base the internal audit plan on a documented assessment of the
organization’s strategies, objectives, and risks. This assessment must
be informed by input from the board and senior management as well as
the chief audit executive’s understanding of the organization’s
governance, risk management, and control processes. The
assessment must be performed at least annually.  
5.2 GIAS Standard 9.4 also states that; The internal audit plan must: 
• Consider the internal audit mandate and the full range of agreed-
to internal audit services. 
• Specify internal audit services that support the evaluation and
improvement of the organization’s governance, risk management,
and control processes. 
• Consider coverage of information technology governance, fraud
risk, the effectiveness of the organization’s compliance and ethics
programs, and other high-risk areas. 
• Identify the necessary human, financial, and technological
resources necessary to complete the plan. 
• Be dynamic and updated timely in response to changes in the
organization’s business, risks operations, programs, systems,
controls, and organizational culture. 
5.3 GIAS Standard 9.5 Coordination and Reliance states that, “The chief
audit executive must coordinate with internal and external providers of
assurance services and consider relying upon their work. Coordination
of services minimizes duplication of efforts, highlights gaps in coverage
of key risks, and enhances the overall value added by providers. If
unable to achieve an appropriate level of coordination, the chief audit
executive must raise any concerns with senior management and, if
necessary, the board.”  The audit plan has been developed with
coordination and reliance on the work of Audit Scotland as the
appointed external auditor, specifically in relation to work on Asset
Management  and Bets Value. However, Coordination and reliance on
other assurance providers including Education Scotland, Care
Commission, health and safety inspectorate, has not been possible for
the 2026/27 plan. Full compliance with this element of the standards
has not been completed as Midlothian Council does not have a full
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assurance map, work towards collection of data that will inform an
assurance Map will be ongoing through 2026/27.   
5.4 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Annual Plan 2026/27 at Appendix 2,
based on the Internal Audit staff resources set out in 6.1. It sets out the
proposed range and breadth of audit activity to be undertaken to
provide the independent and objective audit opinions to Midlothian
Council and the MIJB. 
5.5 As part of the Internal Audit planning process, it was necessary to
consider each organisation’s priorities, plans, strategies, objectives,
risks and mitigating controls, and the internal and external assurances
provided to determine the priorities of the Internal Audit activity
consistent with the organisation’s goals, as follows:
• Analysis was undertaken of Internal Audit work during the past 5
years against the Audit Universe which has been significantly
revised and realigned by the Principal Internal Auditor to reflect
the current strategic and operational management arrangements
and approach to service delivery to ensure appropriate coverage;
• The Strategic Risk Profile was checked to confirm coverage on
key strategic risks, as reliance is placed on the risk assessments
carried out by the Risk Owners taking account of the risk ratings
and mitigations; and 
• The chief internal Auditor completed their own service specific risk
assessments where service risk registers were not mature
enough to place reliance on. 
• All members of the CMT have been asked for input and Directors
provided specific feedback on the planned areas of activity. 
• Account was taken of known external audit and inspection
activities to avoid duplication of assurance work. 
5.6 It is envisaged that 2026/27 will continue to be a year of change for the
Council and other partner organisations. Therefore, the Internal Audit
Annual Plan 2026/27 should be considered to be flexible and will be
periodically reviewed, and amended as required, to reflect any new
arrangement or changing risks and priorities or available resources.
Any amendments relating to the Council will be brought to the
Corporate Management Team and the Audit Committee for approval. 
5.7 The Non-MLC days reflect the Council’s partnership working
commitment to provide Internal Audit resource and services to the
Midlothian Health and Social Care Integration Joint Board (MIJB). A
separate Internal Audit Annual Plan 2026/27 will be presented to the
MIJB Audit and Risk Committee for approval. 
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6 Report Implications (Resource, Digital, Risk and Equalities) 
6.1 Resource 
The Local Authority Accounts (Scotland) Regulations 2014 require a
local authority to operate a professional and objective internal auditing
service. 
Internal Audit must have sufficient staff and other resources to enable it
to carry out the objectives of the Charter and to deliver a programme of
independent and objective audit assurance work alongside other
available sources of assurance to enable the Chief Audit Executive to
prepare annual opinions on the adequacy of the overall control
environment for Midlothian Council, and the MIJB. 
The Internal Audit staff resource totalling 2.61 FTE comprises Service
Manager Internal Audit (0.25 FTE the other 0.25 FTE on counter fraud),
Principal Internal Auditor (0.36 FTE with the other 0.36FTE on counter
fraud) and 2 Auditors (2FTE). Each member of the current Internal
Audit team has a professional internal audit or accountancy
qualification, and has suitable experience, knowledge, skills and
competencies (Including knowledge of GIAS and the Seven Principles
of Public Life) needed to deliver the Plan. After deduction for estimated
annual leave, public holidays, absence, this equates to a total of 511
days available for Internal Audit activity (2025/26 plan 511 days). 
6.2 Digital 
There are no digital implications arising from this report. 
6.3 Risk 
Key components of the audit planning process include a clear
understanding of the Council’s functions, associated risks, and
potential range and breadth of audit activity for inclusion within the
plan. As in previous years, to capture potential areas of risk and
uncertainty more fully, reference has been made to the Strategic Risk
Profile and key stakeholders have been consulted to make an
appropriate assessment of service level risks. 
At all times, Management’s responsibilities (led by the Corporate
Management Team) include:
o Designing and maintaining proper risk management, governance
and internal control processes and systems for which they have
responsibility to ensure probity in systems and operations,
including the prevention, detection and resolution of fraud and
irregularities. These are not fixed but evolve as the Council
changes.
o Checking that these governance arrangements and internal
controls are operating effectively and obtaining assurances from
internal compliance, risk, inspection, quality, and control functions.
(The above are known as the first and second lines.)
o Engaging with Internal Audit (the third line) in a positive way to
achieve shared goals for robust internal control and governance,
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best value and improvement, and ensuring that Internal Audit can
properly fulfil its role.
o Considering and acting upon Internal Audit findings and
recommendations, including implementation of audit
recommendations within agreed timescales and updating Pentana
performance system, or accepting responsibility for any resultant
risk from not doing so.
o Seeking advice and consultancy support from Internal Audit on
existing controls and on changes to and transformation of
governance, processes and procedures. 
6.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance with Global Internal Audit Standards. 
6.5 Additional Report Implications (See Appendix A)
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. These objectives have been considered and
reviewed against each internal audit assignment within the plan. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The purpose of the internal audit function is to strengthen Midlothian
Council’s & Midlothian Integration Joint Board’s ability to create,
protect, and sustain best value by providing the Audit Committee and
management with independent, risk-based, and objective assurance,
advice, insight, and foresight. 
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A.5 Involving Communities and Other Stakeholders 
The Chief Audit Executive is accountable to the Audit Committee
which, in fulfilling its governance role, acts as a bridge between
the Council and other stakeholders. The Audit Committee remit
includes “To approve the risk-based internal audit plan, including
internal audit’s resources requirements, the approach to using
other sources of assurance and any work required to place
reliance upon those other sources”. 
The Council Management Team has been consulted on the Internal
Audit resources, risk-based audit approach and the resultant planned
Internal Audit coverage to ensure it will provide assurance on controls
and governance relating to the key risks facing the Council and to
assist them in discharging their roles and responsibilities. External
Audit plans have been taken into account in completing the planning
process. 
A.6 Impact on Performance and Outcomes 
Applying the framework of the GIAS will give the Audit Committee
assurance that the Internal Audit function is compliant with legislative
requirements and current best practice. 
The delivery of the Internal Audit strategy and annual plan assists the
Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
The Internal Audit Service will continue to annually review compliance
with GIAS to ensure that the service is compliant with legislative and
regulatory requirements as well as best governance practice in the
public sector. 
Specific audits within the 2026/27 plan will include assessments on
when a preventative approach can be adopted by the Council. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Internal Audit is a key element of good governance which
is important to enable Midlothian Council to achieve its objectives
including sustainable outcomes.
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INTERNAL AUDIT STRATEGY         APPENDIX 1 
1. STRATEGIC VISION 
1.1. The vision of this strategy is to guide Midlothian Council (MC)  Internal Audit function in delivering a high-quality
internal audit service to MC and Midlothian Integration Joint Board (MIJB), which is capable of: 
• providing the statutory annual assurance and audit opinion on the adequacy of each organisation’s risk
management, internal control and governance arrangements to the relevant organisation’s senior
management and board/audit committee; 
• carrying out all other objectives contained in Internal Audit’s Charter; and 
• adding value to each organisation by influencing and offering ways to enhance the governance and internal
control environment in alignment to their strategic priorities. 
2. STRATEGY OBJECTIVES AND SUPPORTING INITIATIVES
2.1. The objectives of this strategy are to: 
• Outline the assurance framework which comprises assurances from within the organisation and from
external providers of assurance to improve the organisational understanding of the expectations of Internal
Audit; 
• State how the key themes which are integral to the assurance gathering process across the organisation’s
activities will be covered to inform the annual audit opinion statement; 
• Describe the approach to the development of the risk based Internal Audit annual plan; 
• Set out the relative allocation of Internal Audit resources; 
• Outline how the Internal Audit programme of work will be delivered to add value and will be prioritised to
ensure those areas of greatest risk are covered during the audit year; and 
• Describe the monitoring and reporting of the Internal Audit findings from its work and progress with its
plans to the relevant organisation’s audit committee/board. 
2.2 These objectives are underpinned by a suite of supporting initiatives outlining the key steps to drive delivery.
The supporting initiatives provide opportunity for Internal Audit staff to develop their competencies, enhance the
optimisation of technology, and provide continuous improvement to Midlothian Council and the Midlothian
Integration Joint Board and enhance the internal audit offering. They are premised on engaging with all appropriate
stakeholders, equipping them to facilitate delivery, empowering them to deliver required outcomes, and embedding
good practice. 
Strategic Objective 1 – Agile Auditing: Innovate to explore a more agile approach to the audit process, building
efficiencies and producing more timely feedback to the organisation. 
Supporting Initiatives: 
• Engage with internal audit staff and the organisation to understand expectations and importance of timely audit
feedback & reporting. 
• Equip internal auditors to deliver high quality internal audit services through a lean, efficient and effective
operating model. 
• Empower internal auditors to operate in an agile manner. 
• Embed behaviours that support an agile methodology. 
Strategic Objective 2 – Optimisation of Standards: Embrace and prioritise conformance and embedding of the
Global Internal Audit Standards in the UK Public Sector and maximising their potential to benefit the organisation
and the internal audit function. 
.
Supporting Initiatives: 
• Engage internal audit staff and key stakeholders to ensure a full knowledge and understanding of the GIAS in the
UK Public Sector. 
• Equip internal audit staff and key stakeholders with the tools and information to discharge their respective
responsibilities within the GIAS in the UK Public Sector. 
• Empower internal audit staff and key stakeholders to act on their respective responsibilities and accountabilities
within the GIAS in the UK Public Sector. 
• Embed the mandatory requirement of the GIAS in the UK Public Sector into all relevant policy, process and
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Strategic Objective 3 – Engagement & Reliance on External Assurance Providers: Further engage with the Council
and its external Assurance providers to build a better understanding of the levels assurance already in place to avoid
duplication of 
• Engage with internal audit staff in utilising reviews and knowledge to identify all external assurance providers 
• Equip auditors with the skills identify external assurance providers and assess the appropriateness of assurance
provided and governance to ensure visibility and control.  and avoid duplication of work.   
• Empower internal auditors to avoid duplication and place and communicate appropriate assurance provision.  
• Embed knowledge of external assurance within a growing assurance map for the council. 
3. ASSURANCE FRAMEWORK 
3.1. It is Management’s responsibility to design and maintain proper risk management, governance and internal
control processes and systems to ensure probity in systems and operations, and mitigation of risks, including the
prevention, detection and resolution of fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining assurances from internal compliance, risk,
inspection, quality, and control functions. These are known as the first and second lines of assurance. Internal Audit,
as the third line of assurance, is the review function which will provide independent assurance on the effectiveness
of the first and second lines of assurance, challenge current practices, recommend best practice and improvements
to lead to a strengthening of the control environment and management of risks, thus assisting the organisation in
achieving its objectives. 
3.2. The organisation’s assurance framework is the means by which the relevant organisation’s Senior Management
and Audit Committee/Board ensures that they are properly informed on the risks of not meeting objectives or
delivering appropriate outcomes and that it has adequate assurances on the design and operation of systems in
place to mitigate those risks. 
3.3. The assurance framework comprises assurances from within the organisation (from Management and
compliance functions, and independent and objective assurance from Internal Audit) and from external providers of
assurance. Examples of the latter include the Accounts Commission, External Audit (Audit Scotland for MC and
MIJB), Education Scotland, Care Inspectorate, Scottish Housing Regulator, and other regulators. 
3.4. The assurances are considered during the annual review of the effectiveness of each organisation’s overall
governance framework carried out by officers of each organisation and supported by Internal Audit. The output is
the Annual Governance Statement which is included within the relevant organisation’s Annual Report and Accounts. 
3.5. Where audit assurance is required on services that are delivered jointly by public sector joint working
arrangements which include the organisation as a partner, these assurances will be sought as appropriate from
partners’ Internal Audit service providers, when these exist and Management. 
4. KEY THEMES INTEGRAL TO INTERNAL AUDIT ASSURANCE 
4.1. Each organisation is responsible for ensuring that its business is conducted in accordance with the law and
proper standards, and that public money is safeguarded and properly accounted for, and used economically,
efficiently and effectively. Fundamentally corporate governance is about the systems and processes, and cultures
and values that are used by the organisation to discharge those responsibilities in a timely, inclusive, open, honest
and accountable manner. This includes: setting the strategic direction, vision, culture and values of the organisation;
effective operation of corporate systems; processes and internal controls; engaging with and, where appropriate,
lead communities; monitoring whether strategic objectives have been achieved and services delivered cost
effectively; and ensuring that appropriate arrangements are in place for the managing risks. 
4.2. The organisation’s statutory financial officer, Section 95 Officer or equivalent, i.e. Chief Financial Officer (MC)
and Chief Finance Officer (MIJB), is responsible for the proper administration of the organisation’s financial affairs.
Under their direction, the organisation’s system of internal financial control is based on a framework of Financial
Regulations (rules and regulations for financial management or administration arrangements linked to other key
financial documents that set out the policy framework, associated strategy, and the more detailed procedures and
guidelines), regular Management Information, administrative procedures (including segregation of duties),
Management Supervision, and a system of Delegation and Accountability. 
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4.3. The continued use of and investment in technology to support service delivery, and digital change and
transformation to improve operations is a key part of the vision for each organisation. Arrangements in place are
underpinned by the overarching framework of the ICT security policy designed to ensure that computer systems are
secure, reliable and conform to nationally agreed standards, and by the Digital Strategy linked to Corporate
Priorities designed to support effective and modern service delivery and to meet service objectives. 
5. APPROACH TO PERIODIC PLANNING 
5.1. The Internal Audit Strategy and the Internal Audit Annual Plan 2026/27 has been prepared in conformance with
the Global Internal Audit Standards to fulfil the requirement to produce the statutory annual assurance and audit
opinion for each organisation. 
5.2. As part of the Internal Audit planning process, it was necessary to consider each organisation’s priorities, plans,
strategies, objectives, risks and mitigating controls, and the internal and external assurances provided to determine
the priorities of the Internal Audit activity consistent with the organisation’s goals, as follows: 
• Analysis was undertaken of Internal Audit work during the past 5 years against the Audit Universe, which
reflects the current strategic and operational management arrangements and approach to service delivery,
to ensure appropriate coverage; 
• The Council and service risk registers have been reviewed to confirm coverage on key risks, as reliance is
placed on the risk assessments carried out by the Risk Owners taking account of the risk ratings and
mitigations;
• Account was taken of known external audit and inspection activities to avoid duplication of assurance work;
however this may fall short of the level of co-ordination required under GIAS standard 9.5 Coordination and
Reliance, as clear plans on 2026/27 planned activity have not been collected from all external assurance
providers for the Council. 
5.3. The audit planning process involves consultation with key stakeholders including discussions with Senior
Management of each organisation to capture potential areas of risk and uncertainty more fully. This is of particular
importance during a period of change and transformation as each organisation responds to new legislation or
service delivery arrangements that might affect plans, priorities and resources. 
6. ALLOCATION OF INTERNAL AUDIT RESOURCES 
6.1. The current Internal Audit staff resource totalling 2.61 FTE comprises Service Manager Internal Audit (0.25 FTE
the other 0.25 FTE on counter fraud), Principal Internal Auditor (0.36 FTE with the other 0.36FTE on counter fraud)
and 2 Auditors (2FTE). Each member of the Internal Audit team has suitable experience, knowledge, skills and
competencies (such as the training on the requirements of GIAS and the Seven Principles of Public Life) needed to
deliver the plan all of the team have a professional internal audit or accountancy qualification. The Available Days
has been amended to reflect the Internal Audit resources after consideration of estimated annual leave, public
holidays, absence, learning and development (including required professional CPD), management and supervision. 
6.2. It is estimated that around 73% of Available Days will be spent on assurance, and legislative and other
compliance activities combined. The Assurance work includes sufficient work across a range and breadth of audit
areas which assure those processes that are currently in place and which Management rely on to deliver services,
and to enable preparation of the required annual audit opinion on the adequacy of the organisation’s control
environment as well as delivery of the Councils Annual Governance Statement and review of previous years work. 
6.3. An estimate of 19% of Available Days will be spent on other activities in support of the Internal Audit function,
the Audit Committee and wider management of the Council in meeting wider objectives as set out in the Internal
Audit Charter. 
6.4. An estimate of around 2% of Available Days will be utilised on Consultancy activities which support
Management in delivering innovation, change and transformation. Management seek this value added activity
during this period of change for Local Government though this allocation reflects a reasonable estimate of what is
actually deliverable within the boundaries of the role of Internal Audit and the resources available. 
6.5. It is estimated that around 6% of Available Days will be spent on the provision of Internal Audit services to
Midlothian Integration Joint Board (MIJB). This reflects MC’s contribution of support resources as governance
arrangements have changed in response to statutory partnership working for the provision of health and social care
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7. APPROACH TO DELIVERY OF PROGRAMME OF WORK 
7.1. To facilitate operational delivery, an Internal Audit Programme of Work will be developed which provides an
indication of when work will be scheduled during the year, taking account of discussions with Senior Management
and the availability of Internal Audit resources. 
7.2. For each Internal Audit, in line with recognised good practice, an Audit Assignment detailing the scope,
objectives and timing will be prepared and agreed with the relevant Head of Service(s) and Service Manager(s) prior
to commencement of Internal Audit fieldwork. Within assurance work: 
• The organisation’s Code of Corporate Governance (ELLC/MIJB) will be used by Internal Audit as an
integrated toolkit to test the extent of compliance. 
• End to end reviews of financial management and administration processes will be undertaken by Internal
Audit to test the extent of compliance (as integral part of protecting public finances, safeguarding assets,
and delivering services effectively and sustainably), and substantive testing of transactions including data
analytics will be carried out where this is possible to ensure completeness and accuracy. 
• The Plans (Financial and Asset Management) to deliver the organisation’s strategies, plans and priorities will
be reviewed against best practice standards. 
• Internal Audit will consider fraud risk and prevention and detection controls, and other appropriate cross-
cutting risks and controls (such as risk management, performance management, community engagement,
equalities, business continuity, and health and safety), highlight examples of effective internal controls, and
share good practice across service areas. 
• The ICT arrangements in place to protect each organisation from attack in relation to data security, integrity
and availability will be tested and ICT Plans will be reviewed to confirm they support delivery of the
organisation’s strategies and priorities. 
• National reports that give rise to introducing best practice arrangements or lessons learned from other local
authorities or other public sector bodies will be considered and applied by Internal Audit to influence and
offer ways to enhance governance and internal controls. 
7.3. The Legislative and Other Compliance work will include testing in accordance with the terms of the funders’
service level agreements or legislative requirements, as part of the wider assurance framework. 
7.4. Within Advisory activities, Internal Audit will add value to the Council as it transforms its service delivery
models, re-designs its business processes, and utilises technology to automate processes by influencing and offering
ways to ensure adequate governance, risk management and internal controls. Internal Audit in its ‘critical friend’
role will provide an independent view and challenge of a sample of programmes and projects, and an objective
assessment of self-evaluation arrangements and improvement that underpin the provision of Best Value, when
resources allow. 
7.5. Other work will include: 
• Carrying out Follow-Up to monitor Management’s progress with implementation of Audit recommendations
to: ensure that improvement actions have been timeously and effectively implemented; check that these
have had the desired effect to manage identified risks; and demonstrate continuous improvement in
internal control and governance; and
• Performing Contingency advisory reviews on specific instruction from Members or Senior Management,
investigations and review of sufficiently important issues highlighted during the year where resources allow. 
8. MONITORING THE WORK OF INTERNAL AUDIT 
8.1. The Global Internal Audit Standards (GIAS) requires periodic reporting on the Internal Audit activity to the
relevant organisation’s Senior Management and Audit Committee/Board. 
8.2. Internal Audit assurance work completed and work in progress, and consultancy and other work for the Council
associated with the delivery of the Plan will be outlined within regular reports to its Audit Committee. Specifically
relating to Internal Audit assurance work, this report will include an Executive Summary of the audit objective, good
practice, findings, recommendations, and audit opinion of assurance for each Final Internal Audit Report issued to
relevant Senior Management in the period. 
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8.3. Regular progress updates on implementation by Management of relevant Audit recommendations will be
reported periodically during the year to the relevant organisation’s Senior Management and Audit
Committee/Board. 
8.4. Internal Audit’s compliance with its Strategy, delivery of its risk-based Annual Plan, and outcomes of
assessment(s) against GIAS will be considered by the Chief Internal Auditor on a regular basis and formally reported
annually to the Council’s Corporate Management Team and the Audit Committee, through the Annual Assurance
Report. 
8.5. The Internal Audit Annual Assurance Report for each organisation (Midlothian Council and MIJB) to their
respective Senior Management and Audit Committee/Board will provide the statutory annual audit opinion on the
levels of assurance based on Internal Audit findings over the year to inform each organisation’s Annual Governance
Statement. 
8.6. The GIAS requires an annual Internal Self-Assessment and an External Quality Assessment (EQA) each five years
by appropriately qualified and independent reviewers to assess conformance with the Global Internal Audit
Standards, as well as performance measurement to assess the internal audit function’s progress toward the
achievement of its objectives and promotion of continuous improvement. The program also will assess, if applicable,
compliance with laws and/or regulations relevant to internal auditing; The Scottish Local Authorities Chief Internal
Auditors Group (SLACIAG) have implemented a “peer review” framework, in which MC participates, as a cost-
effective means of complying with the EQA requirement. Reporting on outcomes includes a statement on
conformance with GIAS and the quality assurance and improvement plan (QAIP) to enable an evaluation of the
Internal Audit quality management framework and to identify opportunities for improvement. 
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INTERNAL AUDIT PLAN 2026/27                                                                                                                                                            Appendix 2 
SERVICE AREAS TO
AUDIT 
ALLOCATED
AUDITOR DAYS 
CURRENT PROPOSED AUDIT ASSIGNMENTS FROM RISK ANALYSIS 
Place 120 Days 
Commercial Rents: Review the processes for ensuring that commercial rents are set collected
and recovered in accordance with best practice and Council Policies and ensure best value and
compliance with rental agreements in place. (Inherent Risk Assessment: High) 
Digital Strategy: Provide assurance that the Governance, Internal Control and Risk Management
processes are in place to deliver, monitor, review and update the Councils Digital Strategy on an
ongoing basis to deliver both functional stability and transformation improvements. (Inherent Risk
Assessment: High) 
Climate Change: Provide assurance that there are appropriate Governance, Monitoring and
review controls in place to provide accurate, complete and timely reporting and review of the
Council’s Climate change strategy and progress towards the strategy and in accordance with
legislative and best practice requirements. (Inherent Risk Assessment: High) 
Health & Safety Building Safeguarding servicing and checks: Ensure that processes are in
place to ensure that all legislative requirements are completed for maintaining Council public
Buildings in an safe and useable state. (Inherent Risk Assessment: High)
.
Children, Young
People & Partnerships 
150 Days 
School Trips: Provide assurance that processes are being maintained to ensure that all schools
trips are evaluated for risk (specifically health & safety, insurance and financial risk), educational
benefit and that the process of approval is maintained for all trips being undertaken in a consistent
and reliable basis. (Inherent Risk Assessment: High) 
Children’s Services outwith area placements: Review of authorisation, review and monitoring
processes to ensure best outcomes for the Children and best value for the Council are in place
and operating as appropriate. 
Education Estate Project Management: Specific reviews of Besslack Community High
School Replacement, Penicuik High School and Shawfair All Through Campus as
individual reviews:   Review the processes in place to ensure effective Council management
processes that ensure that Council core outcomes are being managed in an appropriate manner
to provide assurance that these projects are being managed to ensure Best Value for the Council. 
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SERVICE AREAS TO
AUDIT 
ALLOCATED
AUDITOR DAYS 
CURRENT PROPOSED AUDIT ASSIGNMENTS FROM RISK ANALYSIS 
Chief Executive
Services (Including
Finance) 
30 Days 
Insurance:  Provide assurance that processes are in place to provide effective and best value
insurance for the Council, is operated in an efficient and effective manner, and that there is
appropriate governance and internal control processes to highlight areas of risk that could
decrease the achievement of Best Value with insurance cover. (Inherent Risk Assessment: High) 
Adult Social Work  30 Days 
Resource Planning & Monitoring: Review the Governance and Internal Control Processes for
monitoring the use of available resources and the authorisation processes and planning of best
value use of resources. 
Integration Joint
Board 
30 Days  Time has been allocated for work that will be undertaken by Internal Audit for the Midlothian 
Integration Joint Board (IJB). A separate audit plan will be prepared which will be presented to the
IJB Audit and Risk Committee for approval. 
Review of Previous
Year’s Work 
25 Days  Internal Audit will review the outcome of our previous year’s work to ensure recommendations have
been actioned as agreed and that risks accepted by Management have been properly managed. 
Annual Governance
Statement 
28 Days 
Prepare an annual assurance report for Management and the Audit Committee summarising the
work undertaken by Internal Audit during the year and forming an opinion on adequacy of the
Council’s arrangements for risk management, governance and internal control. Continuous audit
approach on progress with areas of improvement. Annual evaluation of compliance with the Local
Code of Corporate Governance covering the corporate whole and individual Directorates/Services. 
Audit & Governance
Committee Annual
Review
4 Days 
Assist the Chair and Audit & Governance Committee Members with the completion of the Annual
review of the Committee in line with the CIPFA Statement and best practice 
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SERVICE AREAS TO
AUDIT 
ALLOCATED
AUDITOR DAYS 
CURRENT PROPOSED AUDIT ASSIGNMENTS FROM RISK ANALYSIS
Annual Planning 10 Days 
Complete the review of Risk Assessment processes, identification of key risk areas assessment
against the audit universe and identification of the links between the Council Objectives and the
Internal Audit work for the 2027/28 annual audit plan. 
Attendance at Boards
and Committees 20 Days 
Attendance at EMT, CMT, SMT, Audit & Governance Committee, Risk Management and Integrity
Group. 
Advice and
Consultancy  
30 Days 
Consultation on New Systems – for new systems implemented, Internal Audit will provide advice on
internal control matters. 
Helpdesk Enquiry System – Provide guidance and advice to Management and Staff on internal
controls. 
Consultancy – providing advice and consultancy on internal control issues. 
Training  15 Days 
An adequate allocation of budget resources and time will be given to maintaining and improving the
knowledge base and quality of the staff resource. This includes time to attend the Scottish Local
Authority Chief Internal Auditor Group (SLACIAG) and computer audit, fraud and data analytics
subgroups and attend their Conferences, ensure appropriate Ethics and Objectivity training in line
with Global Internal Audit Standards and to ensure that all qualified staff to undertake continuous
professional development in line with institute requirements and provide training towards
qualification when necessary. 
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SERVICE AREAS TO
AUDIT 
ALLOCATED
AUDITOR DAYS 
CURRENT PROPOSED AUDIT ASSIGNMENTS FROM RISK ANALYSIS 
Quality Assessment 
15 Days  The Global Internal Audit Standards that apply to the Council from the 1 April 2025 requires an
annual Internal Quality Assurance review is completed by the Service Manager – Internal Audit on
an annual basis and that the results are reported to the Audit & Governance Committee.   the
Internal Audit section will also be subject to an External Quality Assessment (EQA) at least every
five years, by appropriately qualified and independent reviewers. EQA processes are completed by
inclusion on the SLACIAG peer review process which provides substantial best value in ensuring
this process is completed.   
MLC Administration of
Audit Scotland
Reports 
4 Days  Monitor publication of Audit Scotland reports and co-ordinate submission by Management of Audit
Scotland Reports to the relevant Committee. 
Total  511 Days  This matches to the 2.61 FTE staff resources available for Internal Audit in 2026/27. 
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Audit Committee
Monday 23 February 2026
Item No 5.6 
Counter Fraud Annual Plan 2026/27 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Approve the Counter Fraud Annual Plan 2026/27 (Appendix 1). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
for the proposed Counter Fraud Annual Plan 2026/27 to support the
delivery of the Council’s Counter Fraud Strategy and to demonstrate
compliance with the Council’s Counter Fraud Policy Statement. 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime, and
ensure these are embedded preventative practices as specific changes
associated with the Counter Fraud Strategy approved by Council in
August 2020. 
The Counter Fraud Annual Plan 2026/27 (Appendix 1) sets out the
planned counter fraud activity to support the approach and culture of
the Council in tackling fraud and corruption to deliver the Counter
Fraud Strategy. This will enable the Council to demonstrate compliance
with its Counter Fraud Policy Statement as its commitment to tackling
fraud and reflects the Integrity Group’s assessment of counter fraud
controls. 
Date 2026 
Report Contact:
Duncan Stainbank  
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 A review was carried out in 2019/20 of counter fraud management
arrangements in place and to make improvements in light of the
significant fraud investigations that have occurred within Midlothian
Council in recent years, noting that some are ongoing. 
3.2 The conclusion of the review included a refresh to the corporate policy
and strategy for tackling fraud. A revised Counter Fraud Policy
Statement and Counter Fraud Strategy and proposal to have 2 FTE
Corporate Fraud Officers to deliver the revised Counter Fraud Policy
and Strategy were approved by Midlothian Council in August 2020. 
4        Counter Fraud Annual Plan 2026/27 
4.1 Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime
(including cybercrime and money laundering) and ensure these are
embedded preventative practices as specific changes associated with
the Counter Fraud Strategy approved by Council in August 2020. 
4.2 The Counter Fraud Annual Plan 2026/27 (Appendix 1) sets out the
planned Counter Fraud activity to support the change in approach and
culture for the Council for tackling fraud and corruption to deliver the
approved Counter Fraud Strategy. This will enable the Council to
demonstrate compliance with its Counter Fraud Policy Statement as its
commitment to tackling fraud and reflects the Integrity Group’s
assessment of counter fraud controls (update submitted to the Audit
Committee in January 2022). 
5 Report Implications (Resource, Digital, Risk and Equalities) 
5.1 Resource 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud Team. 
The purpose of the Integrity Group is to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime
and money laundering). The formal establishment of the Integrity
Group with a Terms of Reference (approved by the Audit Committee on
22 June 2020) enables the shift to more holistic working in multi-
disciplinary forums to tackle fraud in a consistent and collaborative way
across the Council.   
The revised Counter Fraud Policy Statement and Counter Fraud
Strategy and proposal to have 2 FTE Corporate Fraud Officers to
deliver the revised Counter Fraud Policy and Strategy were approved
by Midlothian Council in August 2020. The 2 Corporate Fraud Officers
are line managed by the Principal Internal Auditor who reports to the
Chief Internal Auditor.
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Savings will continue to be identified arising from Corporate Fraud
Team activity, which will be stated within the Counter Fraud Annual
Reports presented to the Audit Committee. 
5.2 Digital 
None. 
5.3 Risk 
The Council is committed to minimising the risk of loss due to fraud,
theft, corruption or crime and to taking appropriate action against those
who attempt to defraud the Council, whether from within the authority
or from outside. 
The Counter Fraud Policy Statement sets out the roles and
responsibilities for the prevention, detection and investigation of fraud.
The Counter Fraud Strategy provides a focus on enhancing fraud
prevention and detection to improve Midlothian Council’s resilience to
the risk of fraud. The work undertaken by the Corporate Fraud Team in
collaboration with other Services is designed to reduce the fraud risks
within the Council. 
5.4 Ensuring Equalities 
An Integrated Impact Assessment (IIA) Form was completed as part of
the development of the revised Counter Fraud Policy and Strategy. The
conclusion was that undertaking a Combined Impact Assessment was
not necessary as the policy / proposal has little relevance to equality,
negligible impact on the economy, and no impact on the environment. 
5.5 Additional Report Implications (See Appendix A)
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan (Reducing the gap in economic
circumstances; Reducing the gap in learning outcomes; Reducing the
gap in health outcomes; and Reducing the impact of climate change)
by preventing and detecting fraud, additional resources might be
available to support the Council’s objectives. Any loss of funds due to
fraud, theft, corruption or crime might impact on the ability of Midlothian
Council to achieve its key priorities. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s arrangements for
tackling fraud as set out in the Counter Fraud Policy Statement and
Counter Fraud Strategy that were approved by Council in August 2020. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. The
approved Counter Fraud Strategy states the Council will measure
progress against the CIPFA Counter Fraud Maturity Model as a self-
assessment approach to continuous improvement in order to
continuous improvement to be evaluated, managed and evidenced
demonstrate best value in the use of resources. 
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A.5 Involving Communities and Other Stakeholders 
Ensuring awareness of the Whistleblowing facility to report areas of
concern is important in the approach to tackling fraud. The facility has
been promoted in recent years and is being utilised, as stated in the
Counter Fraud Annual Report that reported outcomes of corporate
fraud activity, some of which arose from whistleblowing received from
staff, those within communities or other stakeholders. 
A.6 Impact on Performance and Outcomes 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud team. Internal Audit provides
advice and independent assurance on the effectiveness of processes
put in place by Management. The Findings and Recommendations
from Internal Audit and Corporate Fraud work which are presented to
the Audit Committee during the year assists the Council in maintaining
and / or enhancing fraud prevention and detection controls. 
A.7 Adopting a Preventative Approach 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime, and
ensure these are embedded preventative practices are specific
changes associated with the approved Counter Fraud Strategy. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance is important to enable Midlothian
Council to achieve its objectives including sustainable outcomes.
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Midlothian Council Counter Fraud Annual Plan 2026/27          Appendix 1
Ref Category Activity Nos of
Days
Commentary
1. Compliance Contractor Oversight 20 Oversight of Contractor arrangements with third parties to assess compliance with
procurement rules.
2. Compliance Corporate Fraud Enquiries 155 Respond to whistleblowing notifications. 
3. Data Match National Fraud Initiative 80 Co-ordinate the NFI exercise across Council services, finalise review and investigate
remaining data matches from 2024/25 exercise, coordinate and finalise provision of data
for 2026/27 exercise.  
4. Compliance Social Housing 30 Social Housing enquiries and investigations.
5. Compliance Council Tax  20 Council Tax enquiries and investigations.
6.  Other Corporate Fraud Policy
Framework
20  Support the Integrity Group with monitoring of policies and procedures review, update
and communication. Assist with the self-assessment of compliance against the CIPFA
code on Managing the Risk of Fraud and Corruption.
7. Other Fraud Risk Assessments 70 Develop a risk assessment process and support operational Service Managers to assess
fraud risks and develop improved mitigating controls to ensure the Council has an ability
to attempt to prove that it has reasonable procedures in reference to the Crime of Failure
to Prevent Fraud. 
8. Other Fraud Awareness Training 40 Develop and staff training modules both for offline and online training across the Council
on Fraud, Bribery and Corruption and assist in the implementation of this training. 
9. Other Integrity Groups 6 Attend and provide support to the Council’s Integrity Group.  
10. Other  Training and Development  20 Time to attend the Scottish Local Authority Investigators Group Meetings and training
from NAFN and other required Council and Risk Management training. 
11.  Other Management & Review 50 Includes management time to review work completed and support thr development of
policies, procedures and staff. 
Corporate Fraud Total 511 
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Audit Committee
Monday 23 February 2026
Item No 5.7 
Strategic Risk Management – Strategic Risk Profile Quarter 3, 2025-26 
Report by Derek Oliver, Chief Officer Place 
Report for Information 
1 Recommendations 
Audit Committee is recommended to: 
• Note the current risk landscape and organisational response to
the most significant risks in Quarter 3, 2025-26 (1st October to
31st December 2025). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide Audit Committee with: 
• An update on the risk responses Midlothian Council has
implemented during Q3 2025/26 to respond to the current risk
climate
• Assurance that Midlothian Council took a proportionate and
planned approach to prepare and respond to the current risk
climate
• The risk evaluation of current strategic risks and opportunities
for the Council 
6th February 2026 
Report Contact:
Derek Oliver, Executive Director – Children, Young People and Partnerships
Derek.Oliver@midlothian.gov.uk 
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3 Q3 Risk Management Overview 
3.1 Midlothian Council has delivered a wide range of services to the people
of Midlothian throughout Quarter 3, 2025-26. 
3.2 The Council continues to manage and review risks recorded within the
Strategic Risk Profile. The work required to maintain the necessary
corporate oversight over the broader strategic landscape continues
through the Risk and Resilience Chief Officer Group and Corporate
Management Team (CMT). 
3.3 Audit Committee should note that there were no new risks added from
the previous Quarter however, as per the request from Audit
Committee, the Strategic Opportunities section was revised to include
Strategic Projects.  The Projects included have a Red category across
their respective Risk Evaluation. Updates on actions taken are included
in the full strategic risk profile (Appendix B). 
3.4 Strategic Risk Profile (SRP) 
The SRP is split into three sections:
• Strategic Issues
• Strategic Risks
• Opportunities 
3.5 STRATEGIC ISSUES - SUMMARY 
Strategic issues Likelihood Impact Score Evaluation 
Q3 2025/26 Q2 2025/26
The Change Programme 5 5 25 Critical Critical
Financial Sustainability 5 5 25 Critical Critical 
3.6 The Change Programme 
The Change Programme remains evaluated at Critical. The financial
challenges of the forecasted budget gap pose a significant challenge
for benefits realisation. Council agreed to a Transformation Blueprint in
June 2023 which is a 5-year transformation plan. 
3.7 Financial Sustainability 
The scale of the financial challenge continues to be reported to the
Business Transformation Steering Group and Council. 
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3.8 STRATEGIC RISKS – SUMMARY 
Strategic Risks Likelihood Impact Score Evaluation
Q3 25-26  Q2 25-26
Financial Sustainability in
Future Years 5 5 25 Critical  Critical
The Long-Term Change
Programme 5 5 25 Critical  Critical
Legal and Regulatory
compliance 5 5 25 Critical  Critical
Climate Change 5 5 25 Critical  Critical
Emergency Planning and
Business Continuity 4 5 20 High  High
Health & Safety/Fire Safety 4 5 20 High  High
Cyber Security 4 5 20 High  High
Growing Council 4 4 16 High  High
Scottish Child Abuse
Inquiry 4 4 16 High  High
Asset Management 3 5 15 Medium  Medium
Cost of Living Crisis 3 5 15 Medium  Medium
Counter Terrorism 3 4 12 Medium  Medium
Employee Performance 3 4 12 Medium  Medium
Care at Home 3 4 12 Medium  Medium
Governance and Standards 2 4 8 Low  Low
Internal Control
Environment 2 3 6 Low  Low
Corporate Policies and
Strategies 2 3 6 Low  Low 
3.9     STRATEGIC RISKS – RATED CRITICAL/HIGH 
3.10 Financial Sustainability in future years
The scale of the financial challenge continues to be reported to
Business Transformation Steering Group and Council. 
3.11 The Long-Term Change Programme
The Change Programme has remained at Critical for the last 2 years.
The financial challenges of the underlying budget gap pose a
significant challenge. Council agreed to a Transformation Blueprint in
June 2023 which is a 5-year transformation plan.
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3.12 Legal and Regulatory compliance
Significant resourcing pressures have impacted on risk evaluation. 
Work is ongoing with the Scottish Information Commissioner and
National Records of Scotland to develop and deliver improvement
plans. 
3.13 Climate Change 
Councillors were presented with a briefing on the Climate Action Plan
in Q2 24-25 as committed to through the Transformation Blueprint. 
With a report presented to October Council, Councillors approved,
given the challenges (particularly financial), the realignment of the
target deadline of 2030 for net zero emissions from the Midlothian
Council estate to 2045.  In light of this, a refresh of the Council’s
Climate Change Strategy, approved by Council in August 2020, is
progressing. 
3.14 Emergency Planning and Business Continuity
Ongoing monitoring of a changing landscape and maintaining
organisational readiness and preparedness. Increase in evaluation
score aligned to internal audit of Risk Management, specifically in
relation to a focus on lack of resource, service risk registers and
business continuity planning, as previously reported to Committee.
Service review remains pending. 
3.15 Health and Safety/Fire Safety
New Head of Establishment Fire Information Handbook, Fire
Evacuation Plan template and Fire Logbooks rolled out with emphasis
on need to complete/update plans urgently. Estate Safety &
Maintenance Groups refreshed to identify and action any priority safety
or repairs matters. Health, Safety & Resilience service review
progressing. 
3.16  Cyber Security
With the current climate and intelligence, the overall evaluation is High. 
Our teams remain vigilant and have in place necessary cyber resilience
action plans and certification. 
3.17 Growing Council
The risk evaluation remains High in Q3 2025-26. This is in response to
the current financial challenge as described above and the increased
pressure the Council faces with growth. Some current examples of this
include:
• Inflationary impact on the delivery of the capital programme
• Cost of living crisis 
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• Pressure on the care sector as people are living longer and
require more care provision
• General population growth places additional demand on
infrastructure such as GPs, schools, waste services etc. 
3.18 Scottish Child Abuse Inquiry (SCAI)
The SCAI risk evaluation remains High as the Inquiry continues. 
3.19 STRATEGIC OPPORTUNITIES 
3.20 Capital Projects - Housing
Projects impacted with 26% reduction in Affordable Housing Supply
Programme grant to Midlothian and continued high build costs.  Phase
5 housing programme has been reviewed to ensure affordability within
the Housing Revenue Account, allowing for reduced levels of grant. 
Projects highlighted with specific Red Risk Evaluation(s) and detailed
within the SRP are Newbyres, Gorebridge; Edmonstone Road,
Shawfair and Newton Church Road, Danderhall. 
3.21 Capital Projects – Transport, Net Zero & Infrastructure
Cost of delivering enabling infrastructure projects has risen, resulting in
significant funding gap emerging and impacting on progress of A701
Relief Road, Sustainable Transport Corridor and Straiton Junction
Improvements, which are detailed within the SRP. 
3.22 Capital Projects – Children, Young People & Partnerships Estates 
Programme: Primary 
1. Mayfield/St Lukes PS New Build: Contract signed and financial
close reached June 2025. Construction of the campus well under
way and Phase 1 due for completion April 2027.
2. Kings Park PS Extension & Refurbishment: No available budget to
undertake extension. Condition and suitability of school to be
addressed.
3. Rosewell PS Extension: No available budget to undertake
extension. Condition and suitability of school to be addressed. 2
modular classes were added in August 2024.
4. Mauricewood PS Extension & Refurbishment: Rising roll and
catchment review requires investment in school to address capacity
and suitability. Limited budget available.  Design team appointed to
develop investment in school that aligns with budget available from
Developer Contributions. Tender for 6 class extension and
additional games hall due to be returned in February and will a
report will be brought to the relevant governance board.
5. Bilston PS Extension: Rising roll and catchment review requires
investment in school to address capacity and suitability. Contract
signed and financial close reached January 2026. 4 class extension
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3.23 Capital Projects – Children, Young People & Partnerships 
Estates Programme: Secondary
1. Beeslack HS Replacement:  Contractor appointed. Due to rising
market costs a redesign process is underway.   
2. Shawfair All Through: Site acquisition complete. School location
fixed with design team. Remediation programme due to begin.
Contractor appointed for Campus project. Planning and catchment
consultations are taking place. School due to be complete August
2028.
3. Penicuik HS New Build: Additional budget approved December
2025 allowing construction phase to commence. Project due for
completion Spring 2028 
3.24 Capital Projects – Regeneration
Three specific projects identified within the SRP:
1. Vogrie Changing Places: now progressing .
2. Destination Hillend: Alpine Coaster delivered with access and
parking infrastructure. Project absorbed risk and contingency. 
Delays to delivery resulting from issues with access / water mains.
Main Building tender return exceeded budget. Next Phase to be
recast. Interim works on water supply and drainage required.
3. Hopefield Industrial Estate: Updated financial model required. 
3.25 City Region Deal
Edinburgh and South East Scotland City Region Deal - bid for funding
to Scottish and UK Governments to accelerate economic growth
through investment in infrastructure/ housing/ skills and innovation was
agreed by Council in June 2018.  Projects continue to be progressed
with realisation of regional enhancements and connectivity. 
4 Report Implications (Resource, Digital and Risk) 
4.1 Resource 
There are no direct resource implications indicated in this report,
although individual risks have associated resource implications. 
4.2 Digital 
None 
4.3 Risk 
The risks reported in this report are understood with the Council able to
demonstrate the current risk controls and actions being taken in
response to these.
The report provides an overview of the significant risks faced by the
Council during Quarter 3, 2025-26 and should act to provide assurance
that Midlothian Council took a proportionate and planned approach to
prepare and respond to each of these risks. 
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4.4 Ensuring Equalities (if required a separate IIA must be completed) 
There are no direct equalities issues arising from this report. 
4.5 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Strategic Risk Profile (Quarter 3, 2025-26) 
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APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
This report provides an overview of the Strategic Risk Profile of
Midlothian Council at a defined point in time. The issues, risks and
opportunities affecting or supporting delivery of the council priorities are
set out within the Strategic Risk Profile. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working 
Hub and Spoke 
Modern 
Sustainable 
Transformational 
Preventative 
Asset-based 
Continuous Improvement 
One size fits one 
None of the above 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
The Council’s commitment to best value and securing continuous
improvement can best be delivered when decisions are made against a
backdrop of understanding the risks and opportunities before an
organisation. This report seeks to provide assurance that the current
risk environment is understood and that Midlothian Council is taking
appropriate action in response to those identified risks. 
A.5 Involving Communities and Other Stakeholders 
This Strategic Risk Profile report has been compiled with input from a
range of internal key stakeholders. 
A.6 Impact on Performance and Outcomes 
This report seeks to provide an overview of the challenging risk
environment within which the Council is operating at this time. Being in
a risk aware position helps to inform current and future decision
making, with the intention of enhancing decision making and the
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associated performance and outcomes which flow from well informed
decision making. 
A.7 Adopting a Preventative Approach 
The Risk Management approach being taken by the Council is founded
on a preventative approach to managing risks, where appropriate and
more generally to decision making with far greater risk awareness. 
A.8 Supporting Sustainable Development 
Senior Managers must ensure the sustainability of the Council, which
entails identifying, understanding and managing Strategic and Service
level risks and opportunities.
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
STRATEGIC RISK PROFILE 
SRP This risk register captures the main strategic issues, risks and opportunities that are corporate in nature. It identifies the nature of the risks, measures required to control the risks and their evaluation. It also
details what further actions are required to reduce the likelihood and impacts of those risks to more acceptable and manageable levels with timescales.  
Strategic Issues 
SRP.IR.02 The Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
02
Risk cause
The pace of transformation strands of
activity, reporting to the Business
Transformation Board, does not secure
service transformation, delivery of
outcomes or benefit realisation. 
Risk event
Delayed progress or non-achievement of
outcomes and benefits. 
Risk effect 
Slow or delayed financial benefits arising
from service redesign, requiring the
adoption of recovery plans or requiring
short term service reductions which impact
on the Council’s ability to deliver against
its priorities.
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Transformation Blueprint agreed at Council June 2023 which is a 5-
year transformation plan. Revised governance for transformation agreed
and revised Terms of Reference in place for the Business Transformation
Board to oversee progress on change programme. 
2. Regular reporting to Council setting out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. 
3. Cross Party Business Transformation Steering Group are given
updates on the progress of the Transformation programme. 
4. Financial monitoring reports and work of the Corporate Management
Team evidence continued financial sustainability, in so far as services
are delivered within the overall budget in year.
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.R
A-02.08 Transformation Blueprint 2023-28 delivery
Q3 25/26: As per previous Quarters. Progress with sprints is reported to BTB
at every meeting via the dashboard and also in detailed reports at some points.
BTSG are provided with an updated dashboard every cycle and receive focused
reports on individual sprints and also funding requests to release BT funds to
support project work. 
Chief *Executive;
Chief Officer
*Place; Chief
Officer Corporate
Solutions; Chief
Finance Officer; 
30-Jun-2028  20%
SRP.R
A.02.03i
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 25/26: As Q1 25/26. 
Q2 25/26: As Q1 25/26. 
Q1 25/26: Updated MTFS projections to 2028/29 were presented to Council in
June 2025. A further update will be provided in quarter 3 of 25/26. 
Q4 24/25: MTFS projections to 2028/29 were presented to Council in February
2025 as part of setting the 2025/26 budget and accompanying Council Tax
levels. A further update will be provided to Council during Q1 of 25/26. 
Q3 24/25: An update on the MTFS was presented to Council in December along
with outcomes from the public consultation. Detailed analysis of emerging
national budget positions for 2025/26 was presented and discussed at the
Business Transformation Group. 
Q2 24/25: Further update on the MTFS was presented to Council in October
and a public consultation was launched on 9th October running to 20th
November. 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring
income and to allow the setting of a balanced budget for 2025/26. 
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%           
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.IR.07 Financial Sustainability 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
07
Risk cause
Scottish Government Grant settlements
fall short of the resources needed to
sustain core services. Core funding falling
short of inflation pressures, pay awards
and demographic pressures arising from
an Increasing ageing population of over
75’s. 
Increasing population of 0-15 age group.
Rising customer expectations. 
Risk event
Transformation activity and the flexibility
available to Councils as part of the grant
settlement does not address future years
projected budget gaps. 
Risk effect Inadequate government
funding makes securing balanced budgets
challenging. This in turn erodes the
Council’s ability to deliver services to the
community and potentially means that
resources available fall short of those the
Council assess as required to meet its
statutory obligations. Whilst transformation
activity can help reshape services and
ensure best value in the delivery of
services it is not a solution to continued
erosion of core funding. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. There is an approved Capital Strategy and Reserves Strategy in place.
The Capital Strategy is being updated in the context of ongoing and
significant infrastructure pressures and to reflect completed Asset
Management Plans.. 
2. There is an approved budget for 2025/26. Services are delivered
within the totality of that budget. 
3. Enhanced monitoring arrangements have been agreed for service
areas that are regularly showing overspends. 
4. Directorates have budget boards in place to monitor and agree actions
for those items which are identified as needing specific attention or
present a risk to the financial position of services. 
5. Strategic Boards in place and BTB focus and attention on driving
transformation to support future year’s financial sustainability. 
6. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
7. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 
8. Chief Executive continues to emphasise the need for effective financial
control and underlined the benefit to the organisation of such an
approach.  
9. Scottish Governments May 2022 Resource Spending Review provided
planning parameters for term of parliament, albeit these are challenging
and present a real terms reduction in grant funding of circa 7% over the
period. 
10. Report to Council February 2025 sets out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. Updated MTFS projections presented in June
2025 with a further update to be presented in February 2026.
11. Cross Party Business Transformation Steering Group engaged in
consideration of measures to secure balanced budgets alongside the
development of a Strategic Plan to support decisions about what
services, beyond those which are statutory can be provided.  
12. Income Generation
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.R
A-02.09 Transformation Blueprint 2023 to 2028  Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRP.RA-02.08
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2024  20%
SRP.R
A.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRA.RA-02.08
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
SRP.R
A-02.10 Capital Plan Prioritisation
Q3 25/26: Property & Estates Asset Management Plan moving into delivery
with resource allocated. 
Q2 25/26: Property & Estates Asset Management Plan approved by Council.
Fleet Asset Management Plan and Digital Asset Management Plans are under
development and are key parts of finalising the Capital Plan Prioritisation
exercise. 
Q1 25/26: Work evaluating information flowing from building condition surveys
continues with a view to presenting a draft building Asset Management Plan to
Council in October. 
Q4 24/25: Council in February received an update on Capital Plan Prioritisation
work and made a decision on an updated Learning Estate Strategy. The extent
and affordability of work flowing from building condition surveys is being
assessed and will be concluded and reported to Elected Members early in
2025/26.
Q3 24/25: Work continues on Capital Plan Prioritisation
Q2 24/25: Work continues on Capital Plan prioritisation
Q1 24/25: Work continues on Capital Plan prioritisation 
Chief Finance
Officer; Executive
Director – Place;
Executive Director
- Education
31-Oct-2024  0% 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Strategic Risks 
SRP.RR.01 Financial Sustainability in Future Years
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.01
Risk cause:
Scottish Government Grant settlements
fall short of the resources needed to
sustain core services. Core funding falling
short of inflation pressures, pay awards
and demographic pressures arising from
an Increasing ageing population of over
75’s. 
Increasing population of 0-15 age group.   
Rising customer expectations. 
Policy decisions by UK & Scottish
Governments which are not fully funded. 
Changes to the responsibilities of Local
Government and the funding implication
that arise from that. 
Future year pay award settlements. 
Risk event: 
Real terms reduction in core grant
settlements. 
Policies decisions at Government level not
fully funded to Council's. 
Securing the extent of change required in
order to deliver financial sustainability and
a change program that recognises the size
of the challenge. 
Cost pressures exceeding budget
estimates.
Pressures on increasing insurance
premiums and associated risk
improvement actions.
Risk to not achieving financial
sustainability is a failure to deliver cost
reductions / service change embedded in
the blueprint and also supplementing the
blueprint.
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Maintaining a level of reserves to deal with unforeseen or one-off cost
pressures. 
3. Capital and Reserves Strategies in place. The Capital Strategy is
being updated in the context of ongoing and significant infrastructure
pressures. 
4. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
5. Implement a lobbying strategy with government to recognise the
unique position Midlothian Council is in. 
6. Best Value Audit report actions. 
7. Strategic Boards in place to drive transformation in line with the
Transformation Blueprint. 
8. Risk & Resilience Group and CMT oversight of Insurance Risk
Improvement Actions. 
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability. 
Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRP.RA-02.08
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028  Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRP.RA-02.08
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
SRP.RA
.02.06 Capital Plan prioritisation 
Q3 25/26: Property & Estates Asset Management Plan moving into delivery
with resource allocated. 
Q2 25/26: Property & Estates Asset Management Plan approved by Council.
Fleet Asset Management Plan and Digital Asset Management Plans are under
development and are key parts of finalising the Capital Plan Prioritisation
exercise. 
Q1 25/26: Work evaluating information flowing from building condition surveys
continues with a view to presenting a draft building Asset Management Plan to
Council in October. 
Q4 24/25: Council in February received an update on Capital Plan Prioritisation
work and made a decision on an updated Learning Estate Strategy. The extent
and affordability of work flowing from building condition surveys is being
assessed and will be concluded and reported to Elected Members early in
2025/26. 
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  0% 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.RR.02 The Long-Term Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.02
Risk cause:
A MTFS that does not address the
projected budget shortfall or contextual
factors relating to the Midlothian area. 
Reduced resources 
Leadership fit for the future. 
Lack of clarity or clear compelling vision
for the future 
Delay or shortfall in securing savings 
Lack of or not securing transformational
change in service provision 
Risk event:
Delayed progress in applying various
strands of the Change Programme
including Delivering Excellence
Framework. Slow benefits realisation and
budget savings. Cuts in service provision
rather than service transformation 
Risk effect:
Objectives of change not actually met or
progress too slow. Adverse impact on
services Slow or delayed
proposals/savings arising from service
redesign. Potentially further eroding
reserves or requiring short term service
reductions which impact on Council's
ability to deliver against its priorities. Staff
morale negatively affected, Government
step-in short term savings instead of
transformation  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Leadership from all Elected Members, Executive Team and Senior
Leadership Group. 
3. Appropriate governance in place across the BTB Strategic Boards 
4. Resilience planning. 
5. Capacity to deliver change. 
6. High level priority is given to blueprint work.    
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SPR.RA-02.08
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%
SRP.R
A.02.04 Transformation Blueprint 2023 to 2028
Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRP.RA-02.08
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%  
SRP.RR.03 Legal and Regulatory Compliance 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.03
Risk cause
Current or new legislation applying to
Midlothian Council.
Lack of capacity to resource statutory
obligations around GDPR, data protection,
records management, information
requests and statutory regulatory functions
such as fire safety/health & safety and civil
contingency/business continuity
requirements. 
Risk event
Council and or Services not identifying all
applicable legislation impacting Council
activities and Service requirements. 
Risk effect
Council failing to meet its statutory
obligations resulting in a potential negative
impact for service users or employees. 
Severe financial impacts due to
litigation/prosecution. 
Reputational impact of not meeting
statutory obligations.  
Head of *Adult
and Social Care;
Legal *and
Governance
Manager; Chief
Operating Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Executive Directors, Chief Officer(s) and Head(s) of Service
responsible for identifying applicable legislation and propose Council or
Service responses to CMT and Cabinet/Council as required. 
2. Annual Assurance Statement. 
3. Internal Audit testing of internal controls as part of risk-based audit
plan. 
4. External Audit. 
5. Range of external inspection. 
6. BTSG oversight of new legislation 
7. Central repository of applicable legislation.  
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.03.02 Rights of the Child Bill
Q1 24/25: Bill now adopted. Policy to be presented to Council May/June 2024. 
Council wide group established and developing a plan that ensures we are all
aware and adhering to UNCRC. 
Executive Director
– People  31-Dec-2024  0%
SRP.R
A.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation
Q4 24/25: Standing Orders and Scheme of Administration updated and
approved at Feb 2025 Council 
Legal &
Governance
Manager;
Executive Director
*Place; Chief
Officer Corporate
Solutions;
28 Feb 2027   40%
SRP.R
A.03.07
Review of policy and creation of a policy
register
Q1 25/26: Engagement sessions taking place with each Directorate to review
policy register 
Q4 24/25: Policy list presented to CMT May 2025 for CMT to review and
feedback.
Chief Officer
Corporate
Solutions
31-Dec-2025  40%
SRP.R
A.03.08 Compliance with statutory duties
Q1 25/26: Progress Update Review for Records Management Plan submitted
and approved by National Records of Scotland and published online. 
Compliance Team establishment ongoing. Strategic Information Governance
Group established and Action Plan in development. 
Q4 24/25 : Resourcing proposal for a new Compliance Team being agreed by
Corporate Management Team. Funding to be identified through existing
Corporate Solutions budgets with implementation on a phased basis.  Now
proceeding to final stages of Managing Change process. 
Q1 24/25: Records Management Officer in post and reviewing the Records
Management Plan, Corporate Retention Policy and Schedule and supporting the
development of retention framework for M365 rollout.  
Chief Officer
Corporate
Solutions, Legal
and Governance
Manager 
31-Dec-2025  10% 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.RR.13 Climate Change 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.13
Risk cause
Council Services not adequately engaged,
resourced or directed to fulfil the
requirements of the Climate Change Act. 
Risk event
Council Services not responding to the
Climate Change Act with sufficient pace. 
Risk effect Council failing to meet its
obligation under the Climate Change
(Scotland) Act 2009 and incurring the
associated reputational damage.  
Chief *Executive;
Executive
Directors and
Chief Officers..
1. Statutory requirement to report on compliance with climate change
duties. 
2. Council Carbon Management Plan 
3. Approval of a Corporate Climate Change Strategy and action plan 
4. CPP Board for Climate Change to bring strategic focus and oversight
of plans and progress. 
5. Resilience Seminars
5 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.13.04
Delivery of the BTB Board Carbon Neutral
by 2030
Q1 25/26: Work continues on revised Climate Action Plan/Strategy. 
Q3 24/25: Council approved realignment of Net Zero target from 2030-2045. 
Q2 24/25: Member Briefing delivered. 
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place; 
31-Mar-2030  0%
SRP.RA
.13.05
Development of the Strategic Plan 2023-
27
Q3 24/25:  Council approved realignment of Net Zero target from 2030 to
2045.  Climate Action Strategy refresh to follow. 
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place; 
31-Mar-2025  90% 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.RR.09 Emergency Planning and Business Continuity Management 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.09
Risk cause
The Council not preparing or timeously
reviewing Emergency Plans and testing
arrangements to respond to Civil
Contingencies Incidents. 
Risk event
There are a wide range of potential events
the Council may be expected to respond
to e.g., Severe weather incident,
Pandemic, infectious diseases, utility
disruption etc. 
Risk effect
Loss or degradation of service.
Loss or damage to buildings. 
Not adequately able to recover from the
losses, (e.g. staff, major facility such as
secondary school, main offices or
computer systems etc).
Not able to respond competently to a
major emergency in the community.
Loss of life, livelihoods and property due
to inadequacy of response. 
Reputational consequences and damage.
Prosecution through non-compliance with
the Civil Contingencies Act.
Fatal Accident Inquiries.
Costs.  
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Community Risk Register used to highlight key risks. Council’s plans
developed and maintained in response to identified risks. 
2. Risk and Resilience Group support development, peer review and roll
out of plans. 
3. Establishment and service based contingency plans in place and
maintained.
4. Emergency response plan setting out general approach to respond to
a major emergency in-line with key partner organisations. 
5. As part of the Council’s Emergency response the importance of
recording decisions made and information available at the time is
highlighted as this would be scrutinised in the event of an FAI. 
6. Care for People Group – support for those affected by emergencies
plus various international asylum cohorts.  
4 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.09.02 Development of Emergency Plans 
Q3 25/26: Plans and Procedures updated this quarter:  
Emergency Contacts Directory (reflecting staff changes)  
Severe Weather Plan 
Business Continuity (BC) Planning:  
The draft Corporate BC Plan update reported in Q1 awaiting
approval/comments.  
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31 March 2026   25%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
There are regular, scheduled, meetings with Cyber Security specialists in Digital
Services.  
Midlothian chairs a group of Scottish local authority representatives invested in
BC planning. 
Support to services for Business Continuity activities and enquiries 
Participated in a Business and Digital Services BC Planning Day, facilitated by
Chief Officer Corporate Solutions 
CONTEST/Prevent:  Support is given to the CONTEST and Prevent SPOC on an
ongoing basis, including representation at multi-agency meetings on behalf of
the SPOC.  
Pertinent guidance and information is hosted on the Emergency Planning site on
Mid-Hub.  
Drafted, on behalf of the CONTEST SPOC, the Midlothian Council contribution to
the Lothian and Borders Multi-Agency CONTEST Group’s annual report to
Scottish Government on CONTEST activities. 
Monitoring of progress with the anticipated national guidance relating to The
Terrorism (Protection of Premises) Act, also known as “Martyn’s Law”.  The
guidance is expected to assist organisations comply with the Act. There will be
at least a 24-month implementation period (from April 2025).    
Ongoing routine representation at/participation in:  
Internal meetings requiring a Contingency Planning input  
Torness Emergency Planning Consultative Group meetings and
other Torness multi-agency meetings requiring representation from Midlothian
Council.  
Local Authority Resilience Group Scotland (LARGS) - networking meetings of
resilience practitioners  
General resilience support to colleagues as required.  
Lothian and Borders Local Resilience Partnership meetings (and associated sub-
groups) 
National Community Resilience Group 
Ongoing monitoring and circulation of information and liaison with
services regarding the Public Switched Telephone Network switch-off (in
conjunction with Digital Services).  
Contributed to the development of a Midlothian Community Action information
article on Storms (initiated through the Care for People group). 
Training and Exercising: Coordinated the Midlothian Council response to the
remaining two phases of Exercise Pegasus, the national pandemic
exercise (phase 1 was within the Q2 reporting period).  An exercise report is
expected in due course. 
Coordinated Midlothian Council participation in a table-top exercise coordinated
and facilitated by the Lothian and Borders Multi-Agency CONTEST Group 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Coordinated a severe weather related briefing by a Met Office Civil
Contingencies Adviser to the Managers’ Forum. 
Promulgated information to relevant services on (and attended) a briefing
session relating to Hostile Vehicle Mitigation. 
Promulgated information to relevant services on (and attended) a training
session relating to Resilience Direct which is a Cabinet Office system for sharing
information during planning and response. 
Incidents: Support to Protective Services colleagues and others relating
to Avian Flu outbreak in December 2025. 
Progress with review of emergency plans and business continuity
arrangements remains challenging due to reduced resources.   
Q2 25/26:  As Q1 25/26 for service review.   
Plans and Procedures updated: 
Emergency Contacts Directory (reflecting staff changes)    
Business Continuity (BC) Planning:  
The draft Corporate BC Plan update reported in Q1 awaiting
approval/comments. 
In collaboration with Digital Services, the information on the previous
Emergency Planning and Business Continuity Intranet Portal has been made
available via the front page of Mid-Hub.  There is a specific area for Business
Continuity which will be further developed in the coming months 
There is regular, scheduled liaison with Cyber Security specialists in Digital
Services.    
CONTEST/Prevent:  
Support is given to the CONTEST and Prevent SPOC on an ongoing basis,
including representation at multi-agency meetings on behalf of the SPOC.  
Pertinent guidance and information is hosted on the Emergency Planning site on
Mid-Hub. 
Drafted, on behalf of the CONTEST SPOC, the Midlothian Council response to a
Scottish Government questionnaire relating to Protect and Prepare. 
Monitoring of progress with The Terrorism (Protection of Premises) Act, also
known as “Martyn’s Law”.  National guidance is awaited which will assist
organisations in complying with the Act.  There will be at least a 24 month
implementation period (from April 2025). 
Ongoing routine representation at/participation in:  
Internal meetings requiring a Contingency Planning input, including Care for
People, Estates Safety and Management Groups  
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Support to services for Business Continuity activities  
Torness Emergency Planning Consultative Group meetings and other Torness
multi-agency meetings requiring representation from Midlothian Council. 
Local Authority Resilience Group Scotland (LARGS) - networking meetings of
resilience practitioners  
General resilience support to colleagues as required.  
Lothian and Borders Local Resilience Partnership meetings. 
Undertook/facilitated:  
Ongoing monitoring and circulation of information and liaison with services
regarding the Public Switched Telephone Network switch-off (in conjunction with
Digital Services).     
Training and Exercising:  
Attended information sessions, and provided briefings to senior colleagues, on a
national pandemic exercise scheduled for Autumn 2025.  The exercise takes
place in three phases, the first one was held in Q2, the remaining phases will be
in Q3.  Drafted the Midlothian Council contribution to the Lothian and Borders
Local Resilience Partnership’s response to the Phase 1 scenario.  The exercise is
ongoing.  
Nominations have been submitted for a counter-terrorism exercise is being held
by the Lothian and Borders Multi-Agency CONTEST Group in November 2025.   
Progress with review of emergency plans and business continuity arrangements
has been hindered this quarter due to a combination of the reduced resource
and annual leave. 
Q1 25/26: As Q4 24/25. The service review for the Health, Safety and
Resilience Team Service, which includes Contingency Planning, requires to
progress to implementation stage. 
SRP.R
A.09.03 Business Continuity Software System
Q3 25/26: As Q2 
Q2 25/26: Not renewing Clearview software. Sharepoint to be utilised.
Resource requirements identified within service review for business continuity.
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Dec-2025   25% 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.RR.19 Health & Safety/Fire Safety 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.19
Risk cause
Failing to identify and rectify non-
compliance with Health & Safety and Fire
Safety legislation. 
Risk event
Reactive rather than pro-active
organisational health & safety/fire safety
culture.
Employees/Managers not adequately
trained. 
Employees required to undertake tasks in
which they are not trained or competent. 
Statutorily driven health and safety
protective arrangements for service users
and employees not implemented
sufficiently or correctly. 
Non-compliance with policy and
procedure.
Serious fire leading to loss of life and
property.
Health and Safety team inadequately
resourced to promote or implement pro-
active measures or train managers/staff.   
Audits and inspections not being
undertaken to confirm adherence to policy
and legislative requirements.
Loss of highly experienced staff due to
partial or full retirement.  
Risk effect 
Death, serious injury or ill health impact on
employees and/or service users. 
Loss or damage of Council property.
Negative impact on outcomes for
customers and service users. 
Severe impacts on delivery of services
due to staff absences.
Service users and employees exposed to
hazards where statutory requirements
exist. 
Statutory health and safety duty of care to
services users and employees not met. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Health Safety and Wellbeing Strategy & Service Plan. 
2. Suite of Health and Safety Management Arrangements developed
setting out council response to statutory obligations. 
3. Use of Health & Safety Management Information System (SPHERA) to
enhance information transfer and organisational efficiency. 
4. Training programme in place to support those with responsibility for
managing health and safety.
5. Programme of fire risk assessments.
6. Estate Safety & Maintenance Groups for prioritising any matters
requiring escalation. 
4 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
Statutory notices and/or prosecution by
HSE or SFRS resulting in significant fines. 
Criminal prosecution of the Corporate
body and or individuals through Corporate
Homicide (Corporate Manslaughter). 
Reputational damage.
Significant costs incurred to Council due to
insurance claims, loss of services, plant or
buildings.                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.19.01
Delivery of Health, Safety and Wellbeing
Service Plan
Q3 25/26: Service Plan to follow service review 
Q2 25/26: Service Plan to follow service review. 
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2025  0%
SRP.R
A.19.02 
Health, Safety & Resilience Service
Review 
Q3 25/26: As Q4 24/25. 
Q4 24/25: The service review for the Health, Safety and Resilience Team
Service needs to progress to implementation stage. 
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31/10/2025  0%
SRP.R
A.19.07
H&S fire safety audit across all Council
estate 
Q3 25/26: Progress with fire risk assessments on a priority basis.   
Q2 25/26: Progress with fire risk assessments on a priority basis.   
Q1 25/26: Fire Risk Assessment work plan started – priorities being premises
with sleeping risks, schools, depots, main offices, leisure centres and libraries. 
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2026  20%             
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
SRP.RR.21 Cyber Security  
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.RR.21
Risk Cause
Malicious attempts to damage, disrupt or
gain unauthorised access to Council
computer systems, networks or devices. 
Risk Event
The cyber threat is severe and
advancing quickly. The Council is at
significant risk of cyber-attack from
Ransomware Phishing Emails, Advanced
Persistent Threats (APT) and Distributed
Denial of Service Attacks (DDOS)
attacks. Hacking and Social Engineering. 
Risk Effect
Access to Council systems by cyber
criminals and foreign intelligence
agencies for financial, commercial or
information gathering reasons. This
could lead to significant financial losses,
data compromise and subsequent
regulatory sanction if our technical and
organisational measures are deemed
insufficient. Severe business disruption
including the almost total loss of critical
IT systems and networks leading to
significant service delivery challenges.  
Head of *Adult
and Social Care;
Cyber Security
Information
Governance and
*Compliance
Manager; Head
of *Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Implementation of and compliance with the Scottish Government
Cyber Resiliency Public Sector Action Plan 
2. Cyber Essentials Plus Certification 
3. Public Sector Network Certification 
4. Regular Audits and Inspections
5. Appropriate technical and organisational measures deployed to
reduce the likelihood and impact of an attack 
6. Having adequate skills and knowledge in the organisation 
7. Implementing Scottish Government Cyber Security Action Plan
8. Adoption of the NCSC (National Cyber Security Centre) Active
Cyber Defence programme  
9. Technology upgrades
10. Incident Response plans and exercises
11., Security Operations Centre onboarding
12. Cyber Incident Response onboarding 
4 5 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.21.1 Appropriate Technical and
Organisational Measures 
Q3 25/26: 
Despite the ever increasing cyber security threats, good progress has
continued this quarter, including: 
Cyber Security
Information
Governance and
*Compliance
Manager
31-Mar-2027  75%
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• Appointing a Cyber Incident Response (CIR) company to support the
Council in the event of a cyber attack
• Appointing a third party provider to deliver a Security Operations
Centre (SOC) service, monitoring the Council’s network 24/7, 365
days per year, recognising that cyber attacks often occur outside
normal business hours
• Promoting a different themed cyber security awareness message to
staff each month, alongside ongoing phishing exercise
• Successfully defending the organisation against multiple cyber
attacks
• Providing security oversight for the onboarding of several new
applications and technical services
• Conducting a full day cyber security planning exercise at Danderhall 
Q2 25/26:
Work continues this quarter to maintain and strengthen our cyber security.
Key successes this quarter include:     
• Digital Services completed a detailed DWP security audit.  
• A penetration test of the schools network was conducted 
• Successfully defended the organisation against multiple cyber
attacks. 
• Security oversight was provided for the onboarding of several new
applications and technical services 
• A SOC (security operations centre) and CIR Cyber Incident Response
tender) was prepared and issued   
Q1 25/26 
Work continues this quarter to maintain and strengthen our cyber security.
Key successes this quarter include:     
• Cyber Essentials Plus Certification and PSN Certification were
successfully achieved, demonstrating compliance with national
standards. 
• Successfully defended the organisation against multiple cyber
attacks. 
• A confidential Cyber Defence Briefing Note was submitted to CMT
following high-profile UK cyberattacks, including one targeting West
Lothian’s education network. 
• Security oversight was provided for the onboarding of new
applications and technical service 
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SRP.RR.16 Growing Council 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.16
Risk cause
Population growth in Midlothian over the
next 10 to 15 years will see Midlothian
become the fastest growing Council in
Scotland. 
Between 2014 and 2039, ages 0-15yrs,
population is projected to increase by 20%
and for ages 75+ population projected to
increase by 100%. 
Risk event 
Failure to resource and plan for these
rises will significantly impact the Councils
ability to fulfil its statutory obligations in
relation to these groups. 
Risk effect Inadequate capacity within the
school estate to cope with the projected
increase in pupil numbers. Insufficient
provision to support an aging population
placing costly inefficiencies on other parts
of the care sector. General population
increase placing additional demand on
infrastructure including GP services.
Increased pressure on infrastructure,
services e.g., waste collection and growth
of road network as new development
roads are adopted. 
Head of *Adult
and Social Care;
Chief *Executive;
Executive
Director *Place;
Fiona
*Robertson;
Chief Officer
Young People
and Partnerships
1. Local development plan and supplementary guidance on developer
contributions. 
2. Services planning future service provision on the basis of anticipated
service demands 
3. The change programme 
4. Learning Estate Strategy 
5. Capital Plan Prioritisation 
6. Strategic Housing Investment Strategy 
7. Rent Review Strategy 
8. Joint needs assessment used to develop - IJB Strategic Plan 
9. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 10. City Deal provides the
opportunity to support inclusive growth.  
4 4 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.06 Capital Plan prioritisation
Q3 25/26: Property & Estates Asset Management Plan moving into delivery
with resource allocated. 
Q2 25/26: Property & Estates Asset Management Plan approved by Council.
Fleet Asset Management Plan and Digital Asset Management Plans are under
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  75%
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development and are key parts of finalising the Capital Plan Prioritisation
exercise. 
Q1 25/26: Work evaluating information flowing from building condition surveys
continues with a view to presenting a draft building Asset Management Plan to
Council in October. 
Q4 24/25: Council in February received an update on Capital Plan Prioritisation
work and made a decision on an updated Learning Estate Strategy. The extent
and affordability of work flowing from building condition surveys is being
assessed and will be concluded and reported to Elected Members early in
2025/26. 
SRP.RR.14.1 Scottish Child Abuse Inquiry 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.14.1
Risk Cause: Midlothian Council and its
legacy organisations, predating the
creation of Midlothian Council in 1996,
have been involved in the provision of
care of children going back to living
memory. During this time there is the
likelihood that the care children received
fell below standards of care now in place.
There is the further potential that some
people in the care of Midlothian Council
and its legacy organisations were subject
to abuse by those who were employed to
care for them. 
Risk Event: The Scottish Government
began an Inquiry into cases of Child
Abuse occurring prior to 17 December
2014, the intention of this enquiry is to
identify historic case of abuse which have
to date gone unreported. 
Chief *Executive;
Chief *Social
Work Officer 
The Council initially set up an Inquiry Project Team, however this is no
longer required as we have an experienced worker overseeing all
requests for the Scottish Child Abuse Inquiry Team. 
Work is ongoing and we have the additional tasks of supporting and
responding to enquiries from the redress team. 
The Inquiry Team have established a Project Plan covering: 
1. Residential establishments, List D Schools and Foster Carers:
identifying Children’s homes, Foster Carers and any List D Schools in
Midlothian over the last 100 years and researching historic records. 
2. Record Audit: reviewing the Council’s existing paper and electronic
recordkeeping systems to identify relevant records and map them to
residential establishments. This also includes, where possible, noting the
Council’s historic recordkeeping policies, such as retention schedules. 
3. Cataloguing/Indexing: checking and updating existing recordkeeping
systems for accuracy and consistency, enabling effective information
retrieval when requested by the Inquiry. 
The Project Team have established a Project Plan covering: 
4 4 
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The most recent Section 21 notice around
the Foster Care Case Study is a
significant piece of work. The request for
information from 1930 to date is very
challenging given the volume of files that
require to be read and analysed. 
Risk Effect: If the inquiry finds historic
cases of abuse in Midlothian this could
damage the reputation of the Council and
could place doubt in the eyes of the public
as to the safety of those currently in care.
There is significant scope for a substantial
financial impact arising from claims of
historic abuse. Some existing employees
may be affected by the inquiry and
subsequent claims of abuse. 
To date there has been no evidence from
the extensive file read to suggest there
has been systemic abuse within our foster
care system. 
4. Ascertaining the succession and insurance position in relation to
potential historic child abuse claims. 
5. Ascertaining and agreeing Midlothian Council’s legal position/
approach in dealing with the potential historic child abuse claims. 
6. Identifying the need for guidance, protocol, templates etc. should/if any
claims be made against the council. 
7. Project team is in place with project plan with a range of identified
actions which are being progressed. Monthly meetings to progress
project plan. 
8. The SCAI Social Worker is very competent and experienced in this
area of work and provides quarterly updates on their findings from the file
read. This is a real strength within this area of work. The CSWO and
Principal Solicitor meet regularly with the social worker to discuss
findings from the file read. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.14.03
Foster Care and Residential Care File
Review  Q3 24/25: Phase 10 is now in progress with investigation of residential care
homes run by local authorities. We will comply with all s21 requests. 
Childrens Services
Management
Team; Chief
*Social Work
Officer;  Chief
Officer Young
People and
Partnerships
31-Mar-2024  100% 
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SRP.RR.08 Asset Management – Buildings, Vehicles,  Roads and Digital Assets/Networks 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.08 
Risk cause
Many of the assets the Council own by
their nature are in a position of ongoing
deterioration through their normal use,
e.g., roads - normal wear and tear,
streetlights and vehicles & buildings used
to deliver services. 
Risk event
Many assets will deteriorate under normal
conditions although buildings, roads and
streetlights as an example can be
damaged during more extreme weather
events or as a result of a lack of
maintenance. 
Risk effect
In the case of Roads Services there is a
real risk of increased potholes and
insurance claims, reduced skid resistance
leading to higher accident potential and
building up of higher costs in the future. In
respect of vehicles, increased
breakdowns, service failures, greater
maintenance inevitable, higher short-term
hire costs. In terms of property, health and
safety issues arise, failure to meet current
standards and higher running costs. There
is also the risk of two-tier accommodation,
some high quality, some low. 
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. There is provision in place within the capital plan for investment in the
asset base. 
2. Asset register 
3. Condition Survey 
4. Understanding of future asset needs 
5. Asset Strategy: 
. Roads 
. Land 
. Fleet 
. Digital Service Network 
. Digital Service hardware 
6. Capital programme - investment in estate. 
7. Ongoing monitoring of properties by: Maintenance Surveyors,
Facilities Management and Property Users. 
8. Established Capital Plan and Asset Management Board and dedicated
Asset Management Board 
9. Establishment of 7 thematic Estate Safety and Management Groups
chaired by Chief Officer Place 
10. Building Accessibility Strategy 
11. Completion and approval of Asset Management Plans 
3 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.08.02
Plan for appropriate investment in capital
works and remedial maintenance over the
lifespan of each property asset.
Q3 25/26: Property & Estates Asset Management Plan moving into delivery
with resource allocated. 
Q2 25/26: Q2 25/26: Property & Estates Asset Management Plan approved by
Council. Fleet Asset Management Plan and Digital Asset Management Plans are
Chief Officer
*Place;  30-Apr-2025  33%
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under development and are key parts of finalising the Capital Plan Prioritisation
exercise. 
Q1 25/26: Asset management plan for Property & Estate drafted. Due to be
finalised and issued to Council in Q2. Updated governance for asset
management included. Asset management plans for Fleet also approved at
Council. 
Q3 24/25:  Condition Surveys of Learning Estate (excl PPP) has concluded.  Q4
presentation to Elected Members.  Backlog repairs continue. 
Q1 24/25: Condition Surveys continue, with Learning Estate (excl PPP)
expected to be concluded by end December 2024 to inform capital investment
proposal. 
SRP.R
A.08.05 Learning Estate Strategy
Q3 25/26: Significant progress on SRP, with report to Council to follow in Q4. 
Q1 25/26: Learning Estate Strategy is currently being implemented with the
focus on the delivery of the LEIP funded projects of Mayfield, Beeslack and
Penicuik. The Shawfair Campus project has been approved and design is being
developed. Other non LEIP funded projects have started or are in planning such
as Bilston PS & Mauricewood PS. Updated roll projections (SRP) will inform
future strategy planning. 
30-March 2026  50%
SRP.R
A.08.06
Asset Management systems 
Q3 25/26: Property & Estates Asset Management Plan moving into delivery
with resource allocated. 
Q225/26: Q2 25/26: Property & Estates Asset Management Plan approved by
Council. Fleet Asset Management Plan and Digital Asset Management Plans are
under development and are key parts of finalising the Capital Plan Prioritisation
exercise. 
Q1 25/26: Asset management plan for Property & Estate drafted. Due to be
finalised and issued to Council in Q2. Updated governance for asset
management included. Fleet Replacement Programme approved. 
Head of
*Development; 31-Mar-2025  50% 
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SRP.RR.22 Cost of Living Crisis 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.22 
Risk cause
The UK is currently facing an
unprecedented storm of increasing prices,
bills and tax. A 40-year high inflation rate
of 9% is the main driver of the cost-of-
living crisis which has outstripped wage
and benefit increases. 
Risk event
Rapid ongoing rise of energy prices as
well as food and drink prices. 
Risk effect The impact on households is
already being noted with 87% of adults in
the UK reporting an increase in their cost
of living in April 2022 (Office for National
Statistics; Francis-Devine et al, 2022). The
price rises will impact low-income
households the hardest as a larger
proportion of their bills are on energy and
food.
Chief *Executive;
Director *Health
and Social Care;
Executive
Director *Place
1. Council Cost of Living Task Force to oversee the Council’s response
to the crisis 
2. Allocation of LACER funding to support those most affected 
3. Strategic Evaluation Partner appointed to create poverty profile 
4. Community Planning Partnership has established a Midlothian
Strategic Poverty Prevention Group co-chaired by Council Leader and
Director of Public Health 
5. New Child Poverty chair and lead appointed (Executive Director
Children, Young People and Partnerships) 
6. Child Poverty self-evaluation underway with Improvement Service  
3 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.22.1 Cost of Living Task Force Q1 23/24: Meetings continuing.   Chief *Executive;  31-Mar-2024  100% 
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SRP.RR.23 Counter Terrorism – Compliance with Legislation 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.RR.2
3
Risk cause
Current or new legislation applying to Midlothian Council.
Lack of capacity to resource the statutory obligations. 
Risk event
Council and/or Services not identifying all applicable
actions.
The CONTEST and Prevent action plans fall short of
what is required 
Risk effect
Council failing to meet its statutory duties, potentially
resulting in a negative impact on the safety of employees,
service users and visitors to Council facilities.
Reputational impact of not meeting statutory duties. 
Chief Officer
Children’s
Services,
Partnerships
and
Communities
1. There is a CONTEST Lead and Depute (Single Point of
Contact (SPOC)) in place.  These individuals are also the
nominated Prevent SPOC and Depute SPOC.
2. There are designated, trained officers available to Chair
Prevent related case conferences (Prevent Multi-Agency
Panel).
3. There is a Midlothian CONTEST Group chaired by the Chief
Officer Children’s Services, Partnerships and Communities.
Membership includes representatives from services in both
Council Directorates and the Midlothian Health and Social
Care Partnership plus key external partners.  Terms of
Reference are in place.
4. Executive Directors, Chief Officers and Heads of Service are
responsible for ensuring that their services comply with
allocated actions and identifying any concerns and additional
actins required.
5. An annual report on CONTEST activities is submitted to the
Corporate Management Team.
6. Prevent assurance Statements are required by the Home
Office and Scottish Government every two years.
7. Scottish Government may also require additional CT reports at
various times.
8. Relevant information and updates received from external
partners and organisations are disseminated to CONTEST
Group members and others as appropriate.
9. E-learning CONTEST related modules, including Prevent
products are Mandatory.  In-person and written briefings are
available to other staff groups who do not have access to e-
learning or for whom the full briefing is not appropriate. 
3 4 
Risk Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.23.
01
Review and implement the recommendations from the
Prevent Assurance 2025 process.
Q2 25/26: Feedback with recommendations have been received from Home Office. 
Q4 24/25:  The Home Office is due to provide feedback on the Midlothian Council
Prevent Assurance 2025 submission.  Communication during the process indicated
that guidance would be given in respect of at least one of the assessment areas. 
Chief Officer
Children’s
Services,
Partnerships
and
Communities
June 2026  0%
SRP.RA.23.
02
Terrorism (Protection of Premises) Act 2025:  Implement
the requirements of the Act as they become clear through
Government guidance.
Q4 24/25:  New legislation.  The Terrorism (Protection of Premises) Act 2025 (also
known as Martyn’s law) received Royal Assent on Thursday 3 April.  The Government
intends for there to be an implementation period of at least 24 months before the Act
comes into force. This period will enable those responsible for premises and events to
Chief Officer
Children’s
Services,
Partnerships
2027  0%
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have sufficient time to understand their new obligations, and to plan and prepare
accordingly. 
Whilst those that fall within scope of the Act may wish to consider the requirements,
there is no requirement to comply with them until the legislation comes into force. The
Home Office will publish statutory guidance during the 24-month implementation
period.  
and
Communities    
SRP.RR.04 Employee performance 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.04
Risk cause
Employees not suitably trained/developed
for the roles required of them. 
Limited availability of qualified
practitioners in certain sectors. 
Change program not informed by all key
stakeholders. 
Ageing work force. 
Employees unclear on expected
behaviours. 
Employees constrained to innovate as a
result of management practice. 
Employee productivity rate below the
required level because of ineffective use
of the People Policies particularly
Maximising Attendance. 
Salaries in some functional areas lower
compared to other LA’s resulting in
recruitment issues particularly with trying
to recruit experienced staff. 
Risk event
Employees not engaged/consulted as part
of organisational transformation. 
Experienced employees leaving the
organisation. 
Inability to recruit suitably qualified /
trained staff to fill vacancies negatively
impacting on remaining workforce. 
Unacceptable behaviours demonstrated
by employees. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
HR Strategic
Lead; Chief
Officer Young
People and
Partnerships
Over-riding risk control measure = Focus on having the right people,
here, healthy, performing, behaving and well led via effective utilisation of
the workforce strategy and accompanying action plan. 
Approval of the Council’s Workforce Strategy 2024-2034 which
focuses on the thematic areas below:  
Attendance / Wellbeing
1. Continuing implementation of the Wellness@Midlothian agenda. 
2. Creation of an Employee Health and Wellbeing Strategy and
supporting policy. 
3. Maintaining the Healthy Working Lives Gold Award. 
4. Proactive use of Occupational Health, Midlothian Physiotherapy,
Employee Assistance Programme and the Workplace Chaplaincy
Service. 
5. Change of EAP supplier to ensure provision of best possible service. 
6. Development of progressive People Policies. 
7. Roll-out of mental health training for staff and managers. 
Performance
1. Service-level workforce plans. 
2. Structured, robust, well established ‘Making Performance Matter’
Framework where expected standards of behaviour and Council values
are re-enforced. 
3. Continued re-enforcement of all People Policies involving various
communication methods. 
4. Development of a suite of management information to ensure Service
Managers are informed e.g., turnover, absence levels/reasons etc. 
Organisational Change
1. Policy for Organisational Change includes strong emphasis on early
engagement of employees. 
3 4 
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Stated organisational culture not
consistently reinforced by managers. 
Poor employee performance will stifle
transformational change. 
Risk effect
Difficulties recruiting the right staff. 
Challenges retaining quality staff. 
Low skill levels. 
Low morale, especially during change. 
High absence rates, loss of experience in
service areas. 
‘A Great Place to Grow’ our values
including respect, collaboration, pride and
ownership not realised, potentially
resulting in missing the opportunity to
capitalise on the abilities, experience and
ideas of team members. Poor employee
performance will Exacerbate the financial
challenge. 
2. Redeployment Procedure to ensure maximum chance of successful
redeployment. 
Conduct
1. Resolution Policy encourages early intervention of workplace issues. 
2. Professional standards and values build into the induction process and
management development programme. 
Communication
1. A range of initiatives to keep staff informed of change (Chief
Executive’s weekly email, Connect, All staff emails, tailored team
briefings etc.  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04
Development and Delivery of the Council’s
Workforce Strategy 2024-34 including
analysis of future workforce requirements,
gap analysis and gap closing strategies,
and performance measures and target
setting.
Q1 25/26: Workforce Planning workshops completed with HR/OD team. Next
session with CMT scheduled in September then onwards to Council Senior and
Service Managers for full rollout. 
Q4 24/25: Council approved the Workforce Strategy 2024-2034 in December
2024. Work progressing on the delivery of the first three years through an
agreed action plan. Acting HR Strategic Lead appointed. Two interim posts from
BTB funding are being progressed for Talent and Reward. 
Q1 24/25: Workforce Strategy in development and expected to be presented
to December Council with Action Plan for approval. Audit Scotland external audit
on workforce and digital to be presented to Audit Committee September 2024. 
Chief Officer
Corporate
Solutions 
31 Dec 2027   25%
SRP.RA
.02.05
Recruitment challenges in Procurement
Service leading to contract management
pressures and backlog in procurement
exercises
Q1 25/26: Procurement Manager in place. Additional Procurement Assistant
resource (fixed term) onboarded August 2025. Category management
realignment agreed and handover in progress. Business partnering model to
commence in September 2025. Contract management framework drafted and in
review. Contract register updated quarterly and published online. Pipeline in
development for each category. 
Chief Officer
Corporate
Solutions  31 Dec 2025  10%
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Q4 24/25: Procurement Manager appointed to start on 1 June 2025. Chief
Officer Corporate Solutions to implement an improvement plan and revised work
plan for the service and develop business case for appropriate resourcing.  
SRP.RR.07 Care at Home 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.07
Risk cause
Internal and External providers of Care at
Home services unable to meet service and
quality requirements as a result of a lack
of capacity. 
Risk event
Capacity of Community Support
outstripped by demand. 
Risk effect
There is a risk that patients will have their
discharge delayed because there is
insufficient community supports to enable
timely discharge leading to deterioration in
their health, beds being blocked and
elective operations being cancelled.  
Head of *Adult
and Social Care;
Director *Health
and Social Care
1. Care at Home winter assurance plan and business continuity plan
complete 
2. Development of Care at Home Service Improvement action plan 
3. External commissioning complete and ongoing contract monitoring in
place 
4. External provider audits complete 
5. Re-established Multi-Agency Quality in Care at Home quarterly review
meetings jointly with East Lothian 
6. Weekly provider meetings in place 
7. Additional locum team members and contracts with agency staff in
place 
8. Daily discharge meeting with Multidisciplinary and Multi-agency team
planning to plan and coordinate discharge to ensure care at hone support
in place  
3 4 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.07.01
Independent review of adult and social
care
Q3 24/25: Scottish Government announced in January 2025 that they will not
be proceeding with the National Care Service. 
Q2 24/25: The Scottish Government has initiated a pause on the development
of the NCS. 
Head of *Adult
and Social Care;
Chief *Executive; 
31-Jan-2024  100%       
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SRP.RR.10 Governance and Standards in Public Life 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.10
Risk cause
Code of conduct for Members and
employees’ actions falling short of
International Standards. 
Risk event
Failure in openness, accountability, clarity. 
Risk effect Service, partnerships and
project outcomes not achieved. Non-
compliance with conduct standards and
reduction in standards in public life.  
Legal *and
Governance
Manager; Chief
*Executive; Chief
Officer *Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions
01 Annual Assurance Statement. 
02 Standing Orders 
03 Scheme of Administration 
04 Scheme of Delegation 
05 Elected Member Code of Conduct 
06 Induction programme for new members and ongoing learning and
development programme 
07 Employee Code of Conduct  
2 4 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation
Q4 24/25: Standing Orders and Scheme of Administration updated and
approved at Feb 2025 Council. 
Q1 24/25: Workplan presented and agreed by SOWG in April 2024. Some
changes to SOs and Scheme of Administration presented and approved by
Council in May 2024. 
Legal *and
Governance
Manager; Chief
Officer Corporate
Solutions; 
28 Feb 2027  20%
SRP.RA
.10.03
Review of the employee onboarding and
induction programme
Q1 25/26: Content for online induction now finalised – in design phase prior to
launch in Autumn. Next step is face to face induction programme. 
Q4 24/25: Work ongoing to finalise the refreshed induction programme and
onboarding process 
Chief Officer
Corporate
Solutions
31-Dec-2025  5%             
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SRP.RR.12 Internal Control Environment 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.12
Risk cause
Work procedures/process inadvertently
create the capacity for fraud and waste to
occur. 
Internal Controls requiring more time,
effort or cost than the risk being managed. 
Mangers failing to follow procedures and
keep systems updated with accurate
information. 
Risk event
Persons exploiting opportunities to commit
fraud. 
Waste and errors 
Changing risk landscape associated with
remote working solutions. 
Risk effect
Waste and loss 
Risks over managed with risk controls
costing more than the potential loss being
managed. Increased opportunity for fraud
or financial loss has direct impact on
management information. Has adverse
effect on service performance.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Services have been prompted to consider fraud and waste within
Service Risk Registers. 
2. Risk Management Guide provides direction on the need to balance
time, effort and cost against benefit of risk controls. 
3. Internal Audit examine internal control arrangements based largely on
the risk registers. 
4. Corporate Fraud team in place who assist managers to undertake
fraud risk assessments in their areas (focused on priority areas) and
provide advice and guidance on fraud related matters. Active
participation in the National Fraud Initiative to investigate matches. 5.
Whistleblowing Policy and Counter Fraud Policy in place (subject to
review) with whistleblowing channels available to report concerns
(anonymously if required). 
6. Internal and external assurance. Annual Governance Statement which
involves obtaining assurance from Management over controls in their
Service. 
7. E-learning for staff to complete mandatory training for fraud
awareness. 
8. Regular updates to Audit committee on progress with
recommendations made by Internal Audit. 
9. Remind staff to declare secondary employment/outside interests and
gifts & hospitality 
10. Induction for all new employees (with service exceptions), including
legal, HR, procurement, health and safety. Control at entry to
organisation. 
11. The Integrity Group continues to meet to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime),
maintaining proper risk management, governance and internal control
processes and systems to ensure probity in systems and operations, and
mitigation of risks, including the prevention, detection and resolution of
fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining
assurances from internal compliance, risk, inspection, quality, and control
functions.  
2 3 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.12.04
Review of Serious Organised Crime
(SOC) group
Q2 25/26: A recent change in Police management covering this area has
meant that progress has been delayed. Anticipating re-engagement in Q3. 
Chief Officer
*Place; Health,
Safety &
31-Mar-2025  50%
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Q3 24/25: Draft Strategy devised.  Regulatory safeguards/actions progressing
through Licensing. 
Q1 24/25: Initial meeting with Police is planned to discuss strategy. 
Resilience
Manager   
SRP.RR.11 Corporate Policies and Strategies 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.11
Risk cause
Policies may not match the aspirations of
the Council's Strategic priorities or cultural
perspective. 
Risk event
Policies not monitored may become out of
date. Policies not reviewed to ensure
alignment with strategic priorities. 
Risk effect Policies not monitored could
result in non-compliance with legislation
Policies not aligned to strategic priorities
will inhibit rather than support
implementation of strategic priorities.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Single Midlothian Plan providing overarching direction 
2. Service plans aligned to Single Midlothian Plan. 
3. Leadership team to ensure correct approaches are adopted to get the
right results. 
4. Strategic housing investment plan, submitted to Scottish Government. 
5. Capital Strategy 
6. Integrated Joint Board (IJB) Plan 
7. IJB Strategic needs assessment 8. Midlothian Local Development Plan
2017 – the Council’s corporate spatial strategy.  
2 3 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028
Q3 25/26: Refer to SRP.RA-02.08 
Q2 25/26: Refer to SRP.RA-02.08 
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
SRP.RA
.03.07
Review of policy and creation of a policy
register
Q1 25/26: See comments earlier in SRP. 
Q4 24/25: Policy list presented to CMT May 2025 for CMT to review and
feedback 
Chief Officer
Corporate
Solutions
31-Dec-2025  10%
SRP.RA
.11.05 Antisocial Behaviour Policy Q1 24/25: Member Briefing on Housing and Antisocial Behaviour to be
prepared and presented during Q2, with report to Council to follow.
Chief Officer
*Place;  31-Dec-2024  0%
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Strategic Opportunities 
SRP.OP.08 Capital Projects - Housing 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.08
Cost of delivering Affordable Housing
Supply Programme has risen at faster rate
than available grant to Midlothian and
continued high build costs will affect ability
to deliver housing programme. 
Policy requirement to deliver 25%
affordable on new housing sites under
significant pressure due to grant level not
growing with housebuilding rate. More
sites will be unable to delivery subsidised
homes for rent due to shortfall in grant. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.   
Executive
Director *Place;
Head of
Development
1. Edmonstone Road, Shawfair – Timeline, Budget and Risk impacted
with Stewart Milne entering administration.  However, site now amber
due to appointment of Dundas Building to finish site. Now on site. 
2. Newtongrange Former Pool & Church Hall sites. Requirement to
deliver 3D modular units on site. V limited Scottish suppliers for 3D due
to Connect going into administration. VfM to be examined in tender report
in Q2. 
Phase 5 housing programme has been reviewed to ensure affordability
within the Housing Revenue Account. Grant level now restored which is
to be used for acquisitions to address temporary accommodation
pressures. However, high level of housing delivery and restored grant
insufficient to support all housing sites to deliver subsidised 25%
affordable homes. 
Timeline Budget Risk Resource
A A A G
A A A G 
SRP.OP.09 Capital Projects – Transport, Net Zero & Infrastructure 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Cost of delivering enabling infrastructure
projects has risen, resulting in significant
funding gap emerging. 
Expansion of scope by Transport Scotland
and restrictions on timing of ecology
surveys driving further cost and timing
risks. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
Executive
Director *Place;
Head of
Development  
1. A701 Relief Road
2. A701 Sustainable Trasport Corridor
3. A701 Straiton Junction Improvements 
For all highlighted projects, estimated cost significantly exceeds budget
available to deliver project. 
For all highlighted projects, addressing requirement for investment in
A701 corridor in phases with prioritisation applied. Bush Loan Junction
progressing ahead of remaining programme fully funded by Edinburgh
and South East Scotland City Regional Deal (ESESCRD) funding. 
Timeline Budget Risk Resource
R R R G
R R R G
R R R G
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as parameters on a RAG status, with any
Red classifications identified and reported.  
SRP.OP.10 Capital Projects – Children, Young People & Partnerships Estates Programme: Primary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.  
Executive
Director *Place;
Executive
Director CYPP;
Head of
Development  
1. Kings Park PS Extension & Refurbishment: No available budget to
undertake extension. Condition and suitability of school to be
addressed.
2. Rosewell PS Extension: No available budget to undertake
extension. Condition and suitability of school to be addressed. 2
modular classes were added in August 2024.
3. Mauricewood PS Extension & Refurbishment: Rising roll and
catchment review requires investment in school to address capacity
and suitability. Limited budget available.  Design team appointed to
develop investment in school that aligns with budget available from
Developer Contributions. Tender for 6 class extension and
additional games hall due to be returned in February and a report
will be brought to the relevant governance board. 
Timeline Budget Risk Resource
A R R A
A R A G
R R A A   
SRP.OP.09 Capital Projects – Children, Young People & Partnerships Estates Programme: Secondary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.  
Executive
Director *Place;
Executive
Director CYPP;
Head of
Development  
1. Beeslack HS Replacement:  Contractor appointed. Due to rising
market costs a redesign process is underway.   
Timeline Budget Risk Resource
R A A G  
SRP.OP.09 Capital Projects – Regeneration 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
Executive
Director *Place;   Timeline Budget Risk Resource
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2025 
OFFICIAL
as parameters on a RAG status, with any
Red classifications identified and reported.  
Head of
Development
1. Vogrie Changing Places:  Warrant submission now complete and
awaiting determination before install can go ahead. Part of wider
Vogrie Renewal Strategy. 
2. Destination Hillend: Alpine Coaster delivered with access and
parking infrastructure and Coaster now open. Project absorbed risk
and contingency.  Updated brief issued to SSM for high level site
planning and to brief Members in Q2.
3. Hopefield Industrial Estate: Updated financial model required. Cost
plan for upgrade to infrastructure being developed
4. Dalkeith Asset Rationalisation Programme: Decant of staff to
Fairfield House complete. Contractor appointed however project
now overbudget and being rescoped. 
R A R A
R R R A
R A A G
A R A G   
SRP.OP.04 City Deal 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.O
P.04
South East Scotland Region City Deal - a
bid for funding to Scottish and UK
Governments to accelerate economic
growth through investment in
infrastructure/ housing/ skills and
innovation. 200 Council Houses linked to
the City Deal. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Maintain strong Midlothian involvement through the City Deal
governance structure. 
2. Midlothian City Deal Key Officer (Internal) Group. 
3. Securing best arrangements for Midlothian through close liaison with
partners and conclusion of business cases.  
4 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.O
P.04.02
Realisation of outcomes of respective
workstreams Q2 25/26: Work continues on the relevant programmes.  Executive Director
*Place 31-Mar-2026  10% 
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