From review to reform: making post-implementation reviews count

Post-implementation reviews are meant to answer a simple question: is a regulation still working? Too often, the answer is “not as well as it should” and yet nothing changes.

Why regulations need to be reviewed

Regulations introduced with the best of intentions and backed by solid evidence and analysis can still fail because of unforeseen responses, unintended consequences, or simply because the world changes around them. This is why monitoring and evaluation matters, and why the regulatory cycle does not end when a regulation comes into force.

The ROAMEF cycle and closing the loop

The government's approach to regulation follows the ROAMEF cycle in the Treasury’s Green Book: Rationale, Objectives, Appraisal, Monitor, Evaluate and Feedback.  

Each stage matters, but the final stage of ROAMEF - Feedback - is the one that too often gets missed. Evaluation via post-implementation reviews (PIRs) is supposed to feed back into future policy-making. The cycle only works if that loop is closed.

The gap between review and action

When a PIR concludes that a regulation is not working as well as it should, for example that it is generating unintended costs, failing to meet its objectives, or simply no longer fit for purpose in a changed environment, those findings are important.

PIRs consume resources, but by themselves provide no benefit for businesses, consumers or the public. Unless the findings of a post-implementation review feed through into policy development, such as into revised legislation, updated guidance, or substantive changes to how the regulation operates, the resources spent on the review are wasted.

This is not an abstract concern. The RPC has seen many cases where PIRs clearly identify that a regulation could be improved and where the recommendation to amend is well-supported by evidence, but where no follow-up action has been taken. The problem identified in the PIR continues.

What good follow-through looks like

When a PIR identifies that a regulation needs to change, that finding needs to be owned by the department (or regulator) concerned. Someone needs to be responsible for taking it forward, resource needs to be allocated to it and progress needs to be tracked.

Where legislative or regulatory change is required, it needs to be taken through the appropriate processes and not deferred indefinitely because it lacks the urgency of a new policy commitment.

This requires deliberate decisions at departmental (or regulator) level. Every PIR that recommends change should include:

ownership of the recommendation a proposed action plan for implementing the recommendation a timetable a named accountable team or official a mechanism for tracking progress

It also requires a shift in how PIR findings are treated within the policy development process. The completion of a review should not be the end of a conversation. It should be the starting point for the next one.

How does your department manage feedback from post-implementation reviews? Let us know in the comments and subscribe for more posts.

https://rpc.blog.gov.uk/2026/06/29/from-review-to-reform-making-post-implementation-reviews-count/

seen at 16:34, 29 June in Regulatory Policy Committee.