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Section 25 Statement – Robustness of Estimates, Adequacy of Reserves
and Chief Finance Officer’s Statutory Opinion
1. In accordance with Section 25 of the Local Government Act 2003, I am
required, as the Council’s Chief Finance Officer, to report to the authority on
• the robustness of the estimates made for the purposes of calculating
the budget; and
• the adequacy of the proposed level of financial reserves.
2. This statement sets out my statutory assessment of the Council’s proposed
budget for 2026/27, within the context of the Medium Term Financial
Strategy. In preparing this opinion, I have considered the Council’s
governance arrangements, financial management framework, risk
management processes, the outcome of budget challenge sessions and
assurance activity, and the most up-to-date information available at the time
of drafting. Members are required to have due regard to this statement
when considering and determining the Council’s budget and council tax for
the forthcoming financial year.
3. This is a professional and independent assessment. It does not replace
Members’ responsibility to determine the budget; rather, it is intended to
ensure that decisions are taken with a clear understanding of the financial
risks, uncertainties and dependencies inherent within the Council’s financial
position.
Basis of the Chief Finance Officer’s Opinion
4. The Council enters 2026/27 having experienced a period of weakened
financial resilience. The scale of recent financial pressures, including
demand volatility, under-delivery of savings, and erosion of reserves,
means that the 2026/27 budget is being set within a context of continued
material risk.
5. My assessment of both the robustness of the estimates and the adequacy
of reserves for 2026/27 is therefore contingent upon a number of critical
assumptions and mitigating actions. In particular, this opinion is predicated
on:
• the confirmation by Government of Exceptional Financial Support for
both 2025/26 and 2026/27, on terms sufficient to address the
remaining forecast deficits and to enable the Council to stabilise and
begin to rebuild its reserves to a level that is commensurate with its
financial risk profile; and
• the delivery, to the scale and to the required timescales, of the
savings and income proposals already incorporated within the
2026/27 budget and Medium Term Financial Strategy, in particular
those that are assessed as higher value, higher risk or more complex
to implement;
• a step change in the Council’s track record of savings delivery,
including strengthened grip and governance, clearer accountability,
earlier in-year corrective action where slippage emerges, and
sustained senior leadership oversight;
• the continued operation of robust in-year financial management,
monitoring and escalation arrangements to identify and respond to
emerging pressures at the earliest opportunity.
6. The Council’s current financial position means that the successful
implementation of the above assumptions is critical to the achievement of a
balanced and sustainable financial position. Should these assumptions not
be realised, the Council would need to consider further corrective action
within the financial year. The implications of these dependencies, and the
principal risks that could affect their achievement, are set out in the
sections that follow.
Wider Statutory Framework
7. The requirement for the Chief Finance Officer to report to the authority on
the robustness of the estimates made for the purposes of the budget and
the adequacy of the proposed level of reserves is set out in Section 25 of
the Local Government Act 2003. The purpose of this statutory report is to
ensure that elected Members are fully informed of the financial risks,
uncertainties and dependencies inherent within the budget proposals prior
to taking decisions on the Council’s budget and council tax.
8. Members are required by statute to have regard to the advice contained
within this Section 25 statement when considering and approving the
budget. This does not remove the discretion of the Council to set a budget
different from that advised by the Chief Finance Officer; however, where
this is the case, Members should be clear about the financial risks and
consequences of doing so, and about the actions that would be required
should those risks materialise.
9. The Chief Finance Officer also has separate and distinct statutory
responsibilities under the Local Government Finance Act 1988, including
the duty to make a report to the authority under Section 114 where it
appears that the expenditure of the Council is likely to exceed the
resources available to it. Nothing in this statement constitutes a Section 114
report; however, it is prepared within the context of the Council’s overall
statutory framework and the requirement to maintain a balanced and
sustainable financial position.
Summary Position
10. The Council is setting its 2026/27 budget following a period of materially
weakened financial resilience. Over recent years, a combination of
structural funding pressures, demand and socio-economic volatility, under-
delivery of savings and erosion of reserves reduced the Council’s financial
flexibility to critically low levels. The Internal Audit opinion for 2024/25 was
“No Assurance”, external audit opinions have been disclaimed for three
consecutive years, and the Council has required Exceptional Financial
Support (EFS) to stabilise its position.
11. Significant corrective action is now underway. The Governance Review
Improvement Plan and the Finance Modernisation Programme are
strengthening financial controls, accountability and oversight. The 2026/27
budget incorporates substantial rebasing of previously underfunded cost
pressures, strengthened inflation assumptions in high-risk services, clearer
savings ownership and a reinstated £10m contingency. Flexible use of
capital receipts has been materially reduced, and governance over savings
and forecasting has been tightened. The proposed reserve level, assuming
confirmation of EFS, restores some limited resilience from the critically low
position at March 2025.
12. Notwithstanding this progress, the Council remains in a recovery phase.
The control environment is demonstrably stronger but not yet fully mature.
The effectiveness of recently implemented governance measures must be
demonstrated over a sustained period. The 2026/27 budget is therefore
being set within a context of continued material risk, particularly in demand-
led services such as temporary accommodation, and is dependent upon
disciplined delivery of approved savings.
13. Having considered all relevant factors, I am satisfied that, for 2026/27, the
estimates used in setting the budget are as robust as can reasonably be
achieved given the information available and the strengthened governance
now in place. I am also satisfied that, subject to confirmation of EFS, the
proposed level of reserves is adequate for the purpose of setting a
balanced budget for the year.
14. These conclusions apply to the 2026/27 financial year only. The Medium
Term Financial Strategy identifies a significant residual funding gap in
2027/28 and 2028/29, and further structural action will be required to
secure long-term sustainability. Continued improvement in savings delivery,
demand management and financial governance will be essential to
maintaining and strengthening the Council’s financial resilience
How the Council arrived at the current financial position
15. The Council’s financial resilience has weakened materially over the period
from 2022/23 to 2025/26. This did not arise from a single decision or event,
but from the cumulative effect of structural funding pressures, ambitious
savings assumptions, demand volatility, erosion of reserves, and
weaknesses in financial systems and control.
16. Understanding how the Council reached this position is important not for
attributing responsibility, but to inform the corrective actions now underway
and to ensure that similar weaknesses are not repeated.
Long-term structural underfunding and income base
17. For a sustained period, the Council has operated within funding settlements
that did not fully reflect the scale and complexity of local demand
pressures. When funding was last reviewed in 2013/14, the Council’s
funding was damped by £4.825m, whereby the required funding as
assessed based on needs was not allocated in full and was not
subsequently reset until the recent Fair Funding Review (FFR). Over the
years, this shortfall implicitly grew to the extent of funding that has now
been assessed in the FFR and settlement. While it is now acknowledged
that the Council was relatively underfunded, the benefit of that recognition
is being phased over three years rather than received immediately.
18. In addition, Hillingdon’s local tax base has historically been comparatively
low. Council tax increases in previous years were, on occasion, frozen or
set below the referendum limit permitted by Government. While those
decisions reflected affordability considerations and local priorities at the
time, they limited the growth of the Council’s tax yield relative to authorities
that applied increases at or nearer the permitted threshold. Because the
national funding methodology assumes a broadly standardised level of
local tax when calculating relative resources, authorities that levy below
that notional level retain correspondingly lower locally generated income.
As a result, the Council entered the recent period of heightened demand
and inflationary pressure with a comparatively lower recurring income base
than some peer authorities.
19. In the years preceding this settlement, service demand growth – particularly
within social care and homelessness – outpaced underlying core funding
increases. This created an underlying structural gap between cost
pressures and recurring income. Temporary accommodation costs, in
particular, have been subject to volatility driven by market conditions and
wider economic pressures beyond the Council’s direct control.
20. The local economic context has also influenced the Council’s expenditure
profile. The impact of Heathrow being within the borough means that
Hillingdon as a port authority faces an abnormal pressure from the arrival of
asylum seekers and the repatriation of British nationals from overseas on
the demand for care and housing which is not fully recompensed through
grant income. While not determinative in isolation, these wider contextual
factors all contributed to pressures on both revenue and demand-led
services.
21. The cumulative effect was that budgets increasingly relied upon efficiency
delivery, income growth and transformation at a pace that was challenging
to sustain over consecutive years.
Savings weaknesses
22. In response to these pressures, the Council adopted substantial savings
programmes. For 2025/26 alone, savings totalling £38.8m (including £4.8m
carried forward from 2024/25) were required to deliver the budget. While
the scale of ambition reflected the magnitude of the financial challenge, the
deliverability of certain proposals was not always underpinned by
sufficiently detailed implementation planning or robust contingency
arrangements.
23. In some cases, there was evidence of optimism bias in the assumptions
underpinning savings delivery. Proposals were incorporated on the
expectation that transformation would be achieved within-year, change
would occur at pace, or that external market factors would remain
favourable. Stretch targets on income were applied in some cases that
could not be met. Where these assumptions did not materialise, the
financial impact crystallised as in-year overspends.
24. Ownership and accountability for individual savings proposals were not
sufficiently clear in all cases. This contributed to slippage, and in some
cases undelivered savings were rolled forward into subsequent financial
years, sometimes more than once, compounding delivery risk.
25. The cumulative effect was that the Council’s base budget became
progressively misaligned with actual service delivery and cost drivers. This
has necessitated significant rebasing within the 2026/27 budget to reflect
the true underlying cost of services, particularly in temporary
accommodation and social care. The rebasing process is intended to
ensure that 2026/27 does not commence with structurally understated
budgets.
Use and erosion of reserves
26. As recurring pressures exceeded planned savings delivery, the Council
balanced successive budgets through the use of reserves and other one-off
measures. While reserves exist to manage timing differences and
unforeseen pressures, reliance upon them to balance recurring gaps
progressively weakens financial resilience.
27. Over recent years, General Fund and unfenced earmarked reserves
declined materially, with the General Fund Reserve reaching £1.45m at
March 2025. This level is very significantly below what would normally be
regarded as prudent for a council of Hillingdon’s size and risk profile.
28. The CIPFA Resilience Index, based on 2024/25 outturn data, placed the
Council at the high-risk end of comparator authorities in respect of
reserves, notwithstanding that borrowing levels relative to income are
comparatively under control. This combination of low reserves but a
manageable debt profile indicates that the Council’s vulnerability has
primarily resulted from having to absorb repeated overspends rather than
being the result of excessive borrowing which has been the case for some
Councils in financial distress.
29. The erosion of reserves has reduced flexibility and limited the Council’s
resilience in the face of in-year variances. It has ultimately led to the
reliance on EFS as a stabilisation mechanism.
Data, Systems and Financial Control Weakness
30. Financial resilience was further affected by weaknesses in financial
systems and control during this period. The implementation of Oracle did
not deliver the level of management information and transparency required
for effective budget management and accountability. Reporting capability
and forecast visibility have been hampered, reducing the ability of budget
managers and finance officers to identify the full extent of emerging
pressures at the time of budget setting. Growth and demand modelling has
been weak or non-existent in some cases and has had to be built up,
challenged and refined during the 2026/27 MTFS process.
31. Working paper quality and the financial statements preparation process
have been found wanting and did not meet external audit expectations or
deliver on time under the national backstop regime. As a result, the Council
has received disclaimed external audit opinions for three consecutive
financial years, together with 7 statutory recommendations. While this
outcome in part reflects a national context of audit backlog and structural
audit market pressures, it also indicates the need for improvement in
underlying financial processes and documentation. The closure of the
2024/25 accounts has required external support to deliver and show
improvement, but this ultimately needs to be taken fully in-house with
sufficient capacity and expertise to be able to produce the accounts on time
and to the standards required.
32. In parallel, the 2024/25 Internal Audit annual report set out multiple
weaknesses in elements of the Council’s control environment, citing
concerns with asset management, budget monitoring, rent arrears and
contract management, which all have a bearing on the financial context.
This represented a clear signal that improvements were required across the
organisation in governance discipline, financial oversight and risk
management.
33. An additional consequence of these system and control weaknesses was a
reduced ability historically to see the full projected outturn trajectory at the
time budgets were compiled and approved. Where emerging pressures
were only fully understood after the budget had been approved, the
following year was already on a path to an overspend.
34. Taken together, these factors created a position in which the Council’s
financial strength was materially weakened entering 2025/26. Structural
funding pressures, ambitious savings targets, reliance on reserves and
control weaknesses combined to reduce resilience. The corrective actions
now underway – an improved funding settlement, strengthened
governance, rebasing of budgets, enhanced spend controls, improved
savings ownership, and rebuilding of reserves – are designed to stabilise
the position and place the Council on a more sustainable footing.
Current Governance and Control Environment
35. The Council entered 2024/25 with material weaknesses in elements of its
governance, financial control and oversight framework. These weaknesses
have been acknowledged openly by senior leadership and Members.
During 2025/26, a structured programme of recovery and reform has been
implemented through the Governance Review Improvement Plan (GRIP)
and the Finance Modernisation Programme (FMP).
36. The control environment is demonstrably stronger than at this point last
year. However, it is not yet sufficiently embedded or consistently operating
to conclude that the underlying weaknesses have been fully addressed.
The Council remains in a stabilisation and recovery phase.
Internal Audit, External Audit and Section 24 Recommendations
37. The Head of Internal Audit’s Annual Opinion for 2024/25 concluded that No
Assurance could be provided over the Council’s internal control, risk
management and governance arrangements. This conclusion reflected:
• A significant increase in Limited and No Assurance reviews (52% of
assurance reviews)
• Weaknesses in asset management, contract management oversight
and budget monitoring
• Poor data quality and inconsistent oversight arrangements
• Reduced senior capacity as attention focused on transformation and
savings delivery
• Governance fragmentation at directorate level
38. Internal Audit also assessed the Council’s risk maturity as “Risk Aware”,
indicating that risks are recognised but not yet embedded in a fully
proactive control environment. In response, the Governance Review
Improvement Plan (GRIP) was established in March 2025 as a corporate
response to identified weaknesses. The GRIP is structured around three
workstreams and is being reported regularly to the Audit Committee:
• Financial governance
• Directorate governance
• Constitutional and democratic governance
39. On 24 July 2025 the Council’s External Auditors issued a Value for Money
Update and statutory recommendations under Section 24 of the Local Audit
and Accountability Act 2014. These recommendations were considered and
formally accepted by Full Council in September 2025. The Section 24
recommendations focused on:
• Financial governance and oversight
• Budget setting and savings realism
• Financial management capacity
• Monitoring and accountability
• Medium-term sustainability planning
40. The Council resolved that the actions contained within both the Finance
Modernisation Programme (FMP) and the Governance Review
Improvement Plan (GRIP) would address these recommendations, with
Audit Committee mandated to monitor delivery.
41. In addition, the Council’s accounts have been disclaimed for three
consecutive financial years under the national backstop audit regime.
Whilst the backstop regime is a national issue affecting multiple authorities,
local factors reported by the External Auditors have included:
• Insufficient working paper quality and audit readiness
• Weak reconciliation processes
• Oracle system limitations
• Capacity constraints within finance
42. Significant work has been undertaken over recent months to improve audit
readiness, documentation standards and closedown planning. However,
the restoration of fully assured accounts will require continued
demonstrable improvement and the External Auditors have judged that it
will likely take the Council at least three further complete audit cycles to get
back to a clean audit opinion.
43. As requested by full Council at its meeting in September 2025, progress on
the Section 24 recommendations is formally being reported to the Audit
Committee at each meeting. The recommendations have been wrapped
into the GRIP programme to ensure completeness and coherence of the
activity undertaken, and so combine issues raised by external and internal
auditors alike. Some of the improvements made during 2025/26 include the
following:
• Implementation of enhanced spend control processes
• Clarification of the Council’s current financial position to inform the
budget setting process
• Better understanding of the issues that led to the Council’s budget
variances
• Ongoing work to address issues with Oracle
• An independent review into the Council’s governance processes and
a review of the Constitution
• Increased focus on data quality through consistent and more
detailed dashboard reporting
44. Whilst these actions represent meaningful progress, it will require sustained
implementation and behavioural change over multiple cycles before
assurance levels can be expected to improve materially. The Audit
Committee will report back to full Council in September 2026 on the
progress made.
Financial Governance and Controls
45. Through the Finance Modernisation Programme and the Governance
Review Improvement Plan, a series of strengthened financial controls have
been introduced and embedded during 2025/26. These measures are
designed to restore discipline, improve visibility of risk and ensure that
financial decisions are subject to appropriate challenge before
commitments are made.
46. Enhanced spend controls have been implemented across the organisation.
All invoice-related expenditure is now subject to a templated request and
structured review process, with strengthened non-pay challenge processes
operating at service manager, corporate director and statutory officer level.
Corporate oversight of purchase card usage has also been reinforced to
ensure compliance with financial regulations and to provide clearer audit
trails. These changes are providing improved visibility over expenditure and
ensure early intervention where spending does not align with corporate
expectations of what is necessary spend.
47. Recruitment and staffing controls have similarly been tightened.
Recruitment and staffing panels continue to operate with strengthened
scrutiny of new appointments, secondments, pay adjustments and
temporary staffing arrangements. Establishment changes are therefore now
subject to clearer corporate review to ensure that decisions align with
approved budgets and objectives. Given the scale of workforce expenditure
within the Council’s cost base, these measures are critical to maintaining
financial stability.
48. In areas of significant demand-led pressure, particularly homelessness and
social care, further governance enhancements have been introduced.
Weekly Temporary Accommodation placement review panels now operate
to provide oversight of high-cost decisions and to ensure that value-for-
money considerations are applied consistently and appropriately. High-cost
social care placements have been subject to structured review for some
time already, with defined escalation routes for exceptional cases. These
controls are intended to strengthen cost containment in the areas
presenting the greatest financial volatility and pressure.
49. Improvements have also been made to forecasting and savings
governance. A savings reporting process has been operating for several
months now to ensure service areas are reporting on the progress against
savings. The MTFS process has introduced a more disciplined approach
and together with monitoring reviews is enabling the Council to remove
optimism bias from savings assumptions. All proposed 2026/27 savings
have been subject to review by senior officers, Corporate Directors and
Cabinet Members, and high-value or high-risk savings proposals are
required to be supported by detailed implementation plans that set out
milestones, dependencies and risk mitigations. Corporate Directors fully
own all of the proposals that have been put forward.
50. The flexible use of capital receipts (FCR) assumptions have been reviewed
and any permanent staffing costs previously covered have been built back
into base budgets. The implementation costs of savings proposals have
been identified and only direct incremental costs will be covered by FCR,
bringing the budgeted use of FCR down from £17m in 2025/26 to £3m in
2026/27. These changes are designed to ensure that the savings
incorporated within the budget are realistic, deliverable and transparently
monitored.
51. Collectively, these measures represent a substantive tightening of financial
governance compared to prior years. However, many of these controls
have been introduced within the current financial year and have yet to
operate over a full budget cycle. Their effectiveness will depend not only on
design but on sustained application, consistent managerial discipline and
cultural embedding across the organisation.
Systems, Infrastructure and Financial Management Capability
52. The Council’s financial resilience has been affected not only by funding and
demand pressures, but also by limitations in systems, reporting capability
and financial management processes. The May 2024 implementation of
Oracle did not deliver the level of clarity and accessibility required to
support strong budget holder accountability. Weaknesses in reporting and
reconciliation processes absorbed capacity of finance staff, reduced
confidence in data and limited visibility and understanding of the financial
performance and position during in-year budget monitoring, with
ramifications for budget setting and year-end closedown and audit
procedures.
53. A structured refresh of financial processes is now underway through the
Finance Modernisation Programme. This includes strengthening reporting
within Oracle, enhancing the reliability and usability of the system and the
management information it produces. The objective is to ensure that budget
managers have timely, accurate and intelligible data on which to base
decisions.
54. Work is also progressing to implement a properly functioning Enterprise
Performance Management (EPM) environment. This is intended to improve
forecasting discipline, ownership and accountability of forecasts by budget
managers and one coherent, consistent forecast from the service level
through to the consolidated top-level forecast.
55. Financial closedown and audit readiness processes are being strengthened
in response to the factors contributing to recent disclaimed external audit
opinions. Improved documentation standards, clearer audit trails and more
structured reconciliation processes are being embedded. More work is still
to be done to reduce the reliance on external support to produce an
improved quality set of accounts and to ensure the capacity and capability
of the department are appropriate.
56. Capital governance arrangements are in the process of being reinforced,
but is still a work in progress. A formal structured approach to capital project
business case development and governance needs to be designed and put
in place but will be addressed in 2026.
57. All of these measures represent important structural improvements.
However, sustained effectiveness will depend on consistent application,
strengthened professional capability and the embedding of financial
discipline across the organisation. This is neither an easy or a quick fix and
will depend on consistent application and enforcement from senior
management to ensure improvements are embedded and a culture of
financial governance and responsibility across the organisation takes hold.
The direction of travel being taken is the right one, but many of the
improvements and controls are still in their infancy or not fully in place and
so the control environment is not yet at a mature state. This will require
continued focus and effort over the coming year. The implication for the
2026/27 budget and MTFS is that there are still potential weaknesses
which may have a bearing on the control environment and reporting
mechanisms, hence on the attention, focus, grip and capacity of staff to
deliver all of the improvements required in the coming year, which will be
important in underpinning the long-term financial resilience of the Council.
Robustness of the 2026/27 Estimates
58. The 2026/27 budget has been prepared in materially different
circumstances from prior years. It incorporates a significant rebasing of
expenditure, strengthened inflation assumptions in high-risk areas,
improved savings governance and reinstates a contingency provision in the
base budget.
Inflation
59. Inflation assumptions have been reviewed comprehensively across pay,
contracts, placements, temporary accommodation, energy and transport.
Particular prudence has been applied in high-volatility areas. In both
children’s and adults’ placements, and in temporary accommodation,
inflation assumptions reflect recent trend experience and market conditions.
60. CPI inflation from April 2025 through to December 2025 has averaged 3.6%
although this has dropped back in November and December. The Bank of
England forecasts 3% by Q1 2026 and to near 2% from Q2 2026 onwards.
Past forecasts have not always materialised, especially where predicting a
return to near 2% inflation.
61. The Council has therefore taken the approach of a 3% increase in respect
of staffing related costs and upwards of 2.8% on non-staffing costs, while
adult social care has been applied at 4.8%. These levels ought to provide
sufficient cover on average for increases over the coming year, subject to a
successful reduction in CPI as forecast. Rates assumed in the MTFS drop
down to 2.0% thereafter but will be revisited as part of next year’s process.
Budget Rebasing and Demand Growth
62. Demand-led services continue to represent the most material source of
financial risk. The 2026/27 budget reflects substantial rebasing of
expenditure to align budgets with observed cost pressures and overspends
during 2025/26. Where services have experienced significant overspends
due to non-delivery of savings or demand growth and inflation in excess of
budget, those pressures have been incorporated into the 2026/27 base
budget. This is intended to avoid the problems experienced in the past
whereby cost pressures were only partially reflected at the point of budget
setting, leading to an immediate budget pressure in the new year.
63. Temporary accommodation remains the single largest area of volatility. The
2026/27 budget reflects updated assumptions regarding placement
numbers and unit costs, with further refinement to 2026/27 assumptions
taking place since the consultation budget was proposed. Projections of
temporary accommodation pressures have now been incorporated into
years two and three of the MTFS. The service has been successful at
restraining the impact of inflation during 2025/26 through implementing new
rate caps and considers that this will continue to have an impact next year.
However, a tightening is anticipated in the rental market due to the Renters
Rights Act which will push up inflation and come through fully in 2027/28,
for which a 5% increase has been assumed.
64. Nevertheless, it must be stressed that temporary accommodation demand
does not correlate reliably with demographic growth or other available
indicators. Economic conditions, private sector rental market dynamics,
asylum flows, and national policy changes all materially influence local
demand. As such, forecasting in this area will continue to carry inherent
uncertainty despite improved modelling and greater review and attention
from officers.
Robustness of Savings Proposals
65. The savings incorporated within the 2026/27 budget have been subject to
more rigorous challenge than in prior years. The scale of savings is
reduced by comparison to 2026/27 but remains significant, and delivery risk
is therefore one of the most critical determinants of the achievability of the
2026/27 budget.
66. The proposals put forward in the December consultation budget were
subject to a number of rounds of officer and star chamber review to assess
the realistic achievability of the proposals. This involved officers and
members and covered both savings and demand growth modelling. Scale,
phasing, deliverability, resourcing and potential barriers were all discussed
in the process. These reviews took place over a period of months from
September through to December. The impact of Temporary
Accommodation was removed from the December MTFS on the basis that
this still needed further work to build confidence for inclusion.
67. Since publication of the December consultation budget, a further period of
review and reflection has been undertaken by officers. This has resulted in:
• Reassessment of phasing;
• Explicit identification of implementation costs;
• Adjustment or removal of proposals where deliverability risk was
assessed as too high;
• Identification of additional pressures where challenge determined
that earlier assumptions had been understated, or additional growth
requirements reflected.
68. This iterative review process has increased both growth provision and
pressure recognition in certain areas but has improved realism and
credibility. The final budget therefore differs in a number of respects from
the December consultation position, reflecting ongoing scrutiny and
removal of optimism bias. These changes are set out in Appendix A7 of the
February Budget and MTFS report to full Council.
69. In addition, savings proposals assessed as higher value, higher risk or
more complex are now required to be supported by detailed delivery plans.
The delivery plan template is designed to capture and clarify milestones,
dependencies and accountability. Corporate Directors have explicit
ownership of delivery within their areas, with all savings proposed having
been signed off by the responsible Corporate Director as part of the
process.
70. This strengthened process materially improves the robustness of the
collection of savings compared to prior years. However, it must also be
recognised that the Council’s recent track record in savings delivery has
been inconsistent. Achieving a step change in delivery success will be
essential.
Contingency
71. A £10m contingency has been reinstated within the base budget for
2026/27. This provides capacity to manage in-year volatility (e.g. for
unforeseen external factors, delays to savings, or to exploit an invest to
save opportunity) without immediate recourse to drawing down on the
reserve that is just being rebuilt, and to soften the need for urgent reactive
savings measures which are usually hard to identify and implement at short
notice. The justification for holding a meaningful contingency is borne out
by recent experience and is a key pillar in ensuring budget robustness.
Business Rates
72. Business rates income for 2026/27 has been modelled on the basis of
safety net protection at 100%, limiting downside risk in the event of appeal
volatility or collection shortfall. This provides protection within the coming
financial year.
73. However, under the new business rates reforms, the safety net protection
reduces in 2027/28 and 2028/29. The Council may therefore face greater
exposure to volatility in those years. In addition, steep increases in rates
liabilities for certain businesses under revaluation changes may increase
appeals and collection risk. These factors do not undermine the robustness
of the 2026/27 estimate but represent a potentially material risk in the outer
years of the MTFS. It is likely that the CCA (check, challenge, appeal)
process on valuation will take significant time and for more complex
businesses such as Heathrow the process may take longer than the current
MTFS 3-year profile. This will need to be revisited in future MTFS iterations.
Dedicated Schools Grant deficit
74. The confirmation of 90% grant support towards the accumulated DSG
deficit materially reduces risk in 2026/27 and provides greater forward
visibility. This is a positive development compared to the position reflected
hitherto. Nonetheless, the structural High Needs deficit remains significant
and the number of schools operating in deficit is increasing, with school
reserve balances reducing. Ongoing oversight, continued delivery of High
Needs management initiatives and clear monitoring arrangements will
remain essential.
75. For the purposes of 2026/27, the DSG assumptions are considered
reasonable based on the most recent government announcements and
local modelling. By the time the statutory override ends (which will impact in
2028/29), the 10% allocation to the Council will need to be absorbed. This
is not currently reflected in the MTFS due to the lateness of the
announcement and the work required to model and understand the impact
of this. However, the grant to be received in autumn 2026, anticipated to be
in the region of £69m of the projected £75.5m deficit, will bring offsetting
benefits by means of reduced borrowing costs which by 2027/28 could
amount to c£3m/year and largely offset the anticipated impact of the
residual deficit in 2028/29. If a similar rate of grant followed in 2027/28 and
2028/29, the Council will need to cover £7-8m of residual deficit.
Housing Revenue Account
76. The Housing Revenue Account (HRA) is ring-fenced and legally separate
from the General Fund. In forming my Section 25 opinion, I have separately
considered the robustness of the estimates and the adequacy of reserves
within the HRA.
77. For 2026/27, the Council will apply the permitted rent increase of CPI plus
1%, in line with the Government’s rent policy. This approach supports the
medium-term sustainability of the HRA business plan and partially offsets
the cumulative income reductions arising from the four-year 1% rent
reduction implemented in earlier years. The adopted assumption is
consistent with national policy and provides a reasonable income base from
which to sustain investment in housing stock and compliance with statutory
and regulatory standards, including the Decent Homes requirements.
78. The principal revenue risk within the HRA relates to rent collection
performance. As with other areas of income collection in the Council, wider
cost-of-living pressures continue to present a risk of arrears growth.
Strengthened monitoring of housing rent debt, improved visibility of arrears
and focused recovery processes are being put in place to mitigate this
exposure. The income assumptions for 2026/27 are considered reasonable
based on known collection experience.
79. The HRA capital programme remains substantial and has been subject to a
detailed review of the projects and overall affordability. There is substantial
investment in housing stock planned in order to meet and maintain Decent
Homes standards, which will help manage reactive repairs levels.
Consideration has been given to the level of borrowing required to support
the programme and the long-term sustainability of debt charges within the
30-year HRA business plan. Borrowing levels have been managed to
maintain debt at or below an internal boundary of approximately five times
annual HRA income. In order to remain within this constraint, certain
schemes have been reprofilied or deprioritised. On this basis, and
assuming delivery within approved cost parameters, the capital programme
is considered affordable within current projections.
Key Financial Risks and Sensitivities
80. Notwithstanding the strengthened assumptions underpinning the 2026/27
budget, a number of residual risks remain:
• Temporary accommodation demand growth, which remains volatile
and influenced by external factors beyond the Council’s direct
control.
• Savings delivery risk, particularly in higher-value and transformation-
based proposals, which necessitates an improvement compared to
past delivery success rates
• Council tax, business rates, rent and other income collection
performance, which may all come under pressure as households
and businesses continue to experience cost-of-living impacts.
• Reduced business rates safety net protection in 2027/28 and
2028/29, increasing exposure to appeals and valuation volatility.
• Placement market inflation, particularly in social care.
• Improved governance around the capital programme, to include a
robust business case process to drive more rigorous assessment of
proposed schemes before they are progressed.
81. The robustness of the 2026/27 estimates must therefore be understood
within a framework of high focus, vigilant in-year monitoring and early
corrective intervention. Strengthened forecasting discipline and escalation
will be essential to identifying, escalating and mitigating these risks.
82. While inherent uncertainty remains, particularly in demand-led services, I
am satisfied that for 2026/27 the estimates are as robust as can reasonably
be achieved given current information, governance arrangements and the
scale of external volatility. This judgement applies to 2026/27 only.
Confidence in the robustness of estimates for the outer years will depend
upon sustained savings delivery, effective demand management and
continued embedding of strengthened financial governance, and will
require yet more work over the coming months to identify further savings
and confirm inflation and growth pressures to close the budget gap.
Adequacy of Reserves and Reserves Strategy
83. In forming my opinion on the adequacy of reserves, I have considered their
level, composition and planned use against the scale of financial risk facing
the Council, the volatility inherent within demand-led services, the degree of
uncertainty within the budget, and the Council’s ability to absorb financial
shocks.
84. Reserves are fundamental to financial resilience. They provide a buffer
against unplanned pressures, manage timing differences, and support the
implementation of transformational change. They are not a substitute for
sustainable recurring income and cannot be relied upon to support ongoing
expenditure; once utilised, they must either be replenished or the
underlying position corrected.
85. The 2026/27 budget removes the structural dependency on drawing down
reserves to achieve in-year balance, aside from known timing differences.
Historic position and rate of decline
86. The Council’s reserves position has materially deteriorated over recent
years. The decline commenced in 2022/23 and accelerated thereafter,
although the impact on the general fund balance was not fully evident until
2024/25.
87. Since March 2022, over a four-year period, general fund and unfenced
earmarked reserves (excluding Schools, Public Health and PFI reserves)
have reduced at an average annual rate of £26.5m. Adjusting for c.£11m of
Covid-19 balances held in March 2022, the underlying average annual
reduction is £23.7m. Applying the £36m projected 2025/26 overspend to
the general fund (but not EFS) demonstrates the pace at which reserves
have been eroded.
Table: Annual progression in useable, unfenced reserves
* Excluding Schools, Public Health and PFI ringfenced reserves
88. This decline reflects sustained financial pressures, demand growth
outstripping provision, a more challenging socio-economic context, and
under-delivery against planned savings, in some cases exceeding the
contingency held in the base budget. Recent budgets have also relied on
planned drawdowns of reserves to balance residual gaps. For 2025/26,
£4.2m of reserves were assumed to be available; however, finalisation of
Year Ended
General
Fund
Earmarked
Reserves (*) Total
Annual
Change
31.3.22 26,712 47,740 74,452
31.3.23 26,839 15,969 42,808 (31,644)
31.3.24 26,845 1,941 28,786 (14,022)
31.3.25 1,450 3,167 4,617 (24,169)
31.3.26 (34,550) 3,167 (31,383) (36,000)
the 2024/25 audited accounts confirmed that reserves were insufficient to
support that assumption.
89. In closing the 2024/25 accounts, it was necessary to draw down unfenced
earmarked reserves to preserve a general fund balance of £1.45m at 31
March 2025. Against nearest statistical neighbours, the most recent CIPFA
Resilience Index data (based on 2024/25 outturn) places the Council at the
high-risk end of the range, reflecting the lowest level of reserves within its
comparator group.
90. During 2025/26, as the full extent of prior year pressures became clear and
enhanced challenge was applied to forecasting, the projected deficit moved
from £18.3m at Month 4 to £36.0m at Month 6 – in excess of what had
previously been regarded as a prudent minimum level of reserves. Without
intervention, this would have resulted in negative balances.
Composition and flexibility of current reserves
91. In addition to assessing the robustness of the estimates, I am required to
form a view on the adequacy of the Council’s proposed level of reserves.
This assessment is intrinsically linked to the scale of financial risk described
in the preceding sections. Reserves are a key mechanism for absorbing
financial shocks, managing timing differences and protecting against
unforeseen and materially adverse movements in income or expenditure.
Reserves cannot substitute for structural balance; once utilised, they must
either be replenished or the underlying cost base corrected. Their
adequacy must therefore be considered in light of both current volatility and
medium-term sustainability.
92. Earmarked reserves are held for specific purposes and provide important
targeted mitigation, but offer limited flexibility to manage general financial
risk. The extensive drawdown undertaken in closing 2024/25 has reduced
unfenced earmarked reserves to very low levels, leaving minimal provision
for risks ordinarily covered through such balances, including insurance
liabilities, local plan costs, provider market volatility and business rates risk.
93. These balances will need to be reviewed and rebuilt as part of the 2025/26
closure process. They are not currently provided for within the base budget
and would therefore require support through the proposed EFS
contingency. Assuming confirmation of EFS, the projected position entering
2026/27 would comprise £41.5m of general fund reserves and £11.6m of
unfenced earmarked reserves. However, this earmarked balance would
include:
• £4.4m relating to technical NNDR timing differences;
• £2m in unapplied grant balances;
• £1m reflecting a paper loss on treasury investments;
• a developing provision towards local plan costs; and
• £1m insurance reserve.
94. There is little practical scope to repurpose these balances for unforeseen
risks. The general fund reserve therefore remains the principal source of
financial resilience.
Housing Revenue Account Reserves
95. The HRA reserve is maintained at £15m, consistent with prior financial
plans. The 2026/27 revenue budget projects a surplus position sufficient to
support capital investment and, where appropriate, debt repayment, without
recourse to reserve drawdown. Maintaining a stable reserve position
provides resilience against potential volatility in rent income, inflation in
repairs and maintenance contracts, or regulatory compliance pressures.
Having regard to the scale of the HRA, its income base and associated
risks, the current reserve level is considered adequate.
96. Taking this together with the HRA assumptions and factors reference earlier
in this report, I am satisfied that the estimates underlying the 2026/27 HRA
budget are robust and that the proposed level of HRA reserves is adequate
for the purposes of setting a balanced HRA budget. The HRA does not
present a material financial risk to the wider financial position of the
authority, provided that borrowing, capital delivery and income collection
continue to be managed within the parameters set out above
Role of Exceptional Financial Support in rebuilding reserves
97. EFS is central to stabilising the Council’s reserves strategy. The 2025/26
request addresses the projected £36m overspend and enables the
rebuilding of £40m of general fund and contingency reserves. Some of the
earmarked reserves drawn down to finalise the 2024/25 will also need to be
rebuilt and funded through EFS.
98. In determining an appropriate reserve level, I have assessed the Council’s
overall risk profile, including:
• exposure to demand-led services;
• savings delivery and transformation risk;
• macroeconomic volatility including inflation and interest rates; and
• the Council’s recent track record of forecast variation.
99. On this basis, a target range of £30m to £50m of uncommitted usable
reserves is considered appropriate. A planned level of £41.5m for 2026/27
sits within the middle of this range, providing sufficient headroom while
avoiding excessive reliance on EFS as the sole mechanism for rebuilding
resilience.
100. It is important to note, however, that recent experience demonstrates how
rapidly reserves can be eroded where planning assumptions prove over-
optimistic or savings delivery falters. Two consecutive years of
underperformance have previously depleted balances at a significant rate.
This level of reserves therefore represents recovery rather than strength.
There will need to be discipline in delivery to ensure that the reserve is
protected from a resumption of drawdowns and structural problems.
101. The reliance on Exceptional Financial Support has implications for the
Council’s Capital Financing Requirement and borrowing trajectory. In
preparing the 2026/27 budget and Medium Term Financial Strategy, I have
had regard to the CIPFA Prudential Code and the requirement that capital
expenditure and borrowing remain affordable, prudent and sustainable. The
projected MRP and interest costs arising from capitalised support are
incorporated within the MTFS and are assessed as affordable within the
current revenue projections. The use of EFS is intended to be time-limited
and forms part of a wider recovery strategy. Continued compliance with the
Prudential Code will depend upon delivery of a balanced medium-term
financial plan and avoidance of further structural capitalisation beyond that
currently modelled.
Reserves Adequacy – Conclusion
102. Taking all factors together, and assuming confirmation of Exceptional
Financial Support, the proposed level of reserves for 2026/27 is adequate
for the purposes of setting the budget.
103. This conclusion is conditional on:
• Delivery of approved savings;
• Continued strengthened financial governance;
• Effective in-year monitoring;
• No material adverse demand or inflation shock beyond modelled
sensitivities.
104. The proposed reserve level restores some resilience from the critically low
position at March 2025. However, it does not provide excess headroom.
Sustained improvement in financial discipline and structural balance will be
required to ensure that reserves are protected and strengthened over the
medium term.
105. This assessment of adequacy, like the assessment of robustness of
estimates, applies to 2026/27. The later years of the MTFS remain subject
to further detailed challenge and will require significant actions and bold
policy decisions to secure enduring financial sustainability and resilience,
and thereby be able to safeguard the reserves from a recurrence of past
depletion.
Closing the budget gap across the MTFS period
106. Despite the improved funding settlement, the Council faces a residual gap
in both 2027/28 and 2028/29. By the final year of the MTFS, the projected
shortfall remains £44.5m, even after the full benefit of the phased funding
reform has been incorporated. This scale of gap is material and requires
early, sustained and structural action. Work to identify and appraise options
must commence at the start of 2026/27 to maximise the time available for
consultation, implementation and delivery of the financial benefits.
107. The most significant driver of the medium-term gap is the continued growth
in demand and inflationary cost pressures within temporary
accommodation. As set out earlier, this represents the single largest area of
financial volatility within the revenue budget. The degree to which demand
growth can be stabilised and unit costs controlled will materially influence
the trajectory of the MTFS. Effective mitigation in this area has the potential
to reduce the rate of cost growth, while failure to do so would compound
pressure in later years.
108. The financing consequences of EFS are also built into the forecast. The
combined impact of Minimum Revenue Provision and interest is projected
to reach £12.4m per annum by 2028/29. This represents a structural call on
the revenue budget. Any reduction in the reliance on EFS, either through in-
year underspends or through capital receipts that can be applied to offset
the capitalised deficit, would directly reduce this recurring burden.
109. Given the scale of the remaining gap, all available income and expenditure
levers must be considered.
110. The current Band D Council Tax level of £1,952.38 (£1,462.00 being the
Council’s own element) in 2025/26 remains significantly below both the
national average of £2,280 (£2,236 excluding parish precepts) and outer
London comparators, and the Council’s own element is approximately 14%
lower than the CIPFA statistical nearest neighbour average of 16 London
councils. The budget assumes a 4.99% increase for Hillingdon in 2026/27,
resulting in a Band D charge of £1,534.95. Each additional 1% increase
generates approximately £1.57m on an ongoing basis and compounds over
time. Authorities in receipt of EFS frequently seek increases above the
referendum limit, and this is an option that warrants careful consideration in
the context of Hillingdon’s comparatively low base and medium-term
pressures.
111. A review of local discounts and concessions is also warranted. The
Council’s older persons’ discount is unique nationally and results in
approximately £1m per annum in foregone income. The Council Tax
Reduction Scheme, while an important support mechanism for low-income
households, also includes elderly claimants. The cumulative affordability
and policy implications of these arrangements should be reviewed
alongside the wider budget strategy.
112. Parking concessions, including the Hillingdon First card and 30 minutes’
free parking, represent further areas where policy choices have financial
implications. Many authorities have moved towards more targeted
approaches where free parking is used strategically in specific locations
rather than applied universally. Given the scale of the MTFS challenge, this
area should be reassessed on a cost-benefit basis.
113. A comprehensive review of all traded services is required to ensure that
operating costs are fully recovered and that non-statutory activity is not
being subsidised. Independent benchmarking analysis indicates that the
Council ranks low or very low against comparable outer London authorities
in a range of fees, charges and sales income categories. While the
proposed increases within the 2026/27 budget will narrow some of this gap,
a structured benchmarking exercise during 2026/27 will be necessary to
identify the full opportunity and inform future decisions.
114. A number of income-generating assets have experienced limited capital
reinvestment over recent years. The sustainability of income streams from
theatres, car parks and elements of the operational estate may depend on
targeted investment to maintain attractiveness, efficiency and yield. A
strategic review of asset conditions and maintenance requirements should
therefore run in parallel with wider estate rationalisation and disposal
considerations, ensuring that revenue consequences are fully understood.
115. The remaining £44.5m gap is substantial and cannot be addressed through
incremental savings alone. It will require a combination of structural cost
control, tight demand management, income maximisation, policy review
and disciplined capital and asset strategies. Early option development
during 2026/27 is essential to allow sufficient time for consultation, delivery
and financial benefit.
116. The Council retains options and a range of potential levers, but the scale of
the challenge requires realism, prioritisation and a willingness to consider
decisions that may previously have been deferred. Sustained delivery
discipline will be critical if the MTFS gap is to be closed without renewed
reliance on one-off measures or further erosion of financial resilience.
Summary
117. In discharging my responsibilities under Section 25 of the Local
Government Act 2003, I have considered the detailed savings and
pressures proposals for 2026/27 and the MTFS, the scale and nature of the
financial risks facing the Council, the governance and financial
management arrangements currently in place, the reinstated contingency
provision, the proposed level and composition of reserves, and the reliance
on EFS as part of the Council’s stabilisation strategy.
118. The 2026/27 budget has been prepared in materially more robust
circumstances than in recent years. Structural pressures identified during
2025/26 have been rebased into the 2026/27 position. Savings proposals
have been subject to enhanced challenge and are supported by clearer
ownership and planning. Inflation assumptions in volatile service areas
have been strengthened and a £10m contingency has been reinstated.
Governance, forecasting discipline and corporate oversight continue to be
tightened in response to both internal and external audit findings.
119. It is also necessary to acknowledge that the Council will start 2026/27 from
a period of materially weakened financial resilience: the Internal Audit
opinion for 2024/25”; the disclaimed external audit opinions and statutory
recommendations; reserves reduced to critically low levels at March 2025
and a need for EFS to stabilise the position. Corrective action is well
underway through the Governance Review Improvement Plan and the
Finance Modernisation Programme. While progress is evident, the control
environment should properly be described as strengthened and improving
but not yet fully mature. Consistent application of the revised framework
over a sustained period of time will be required to restore full assurance
confidence.
120. Having considered all relevant factors, I am satisfied that, for the financial
year 2026/27, the estimates used in setting the budget are as robust as can
reasonably be achieved, given the information available at the time of
preparation, the inherent volatility in demand-led services, particularly
temporary accommodation, and the strengthened governance and
forecasting arrangements now in operation. This judgement is contingent
upon confirmation by Government of EFS in line with current modelling, full
and timely delivery of approved savings proposals, and continued
disciplined in-year financial monitoring with early corrective action where
required. It also assumes that no material adverse demand or inflation
shock occurs beyond that which has been reasonably modelled within
current sensitivities.
121. In respect of reserves, and assuming confirmation of EFS, the proposed
General Fund reserve level for 2026/27 is adequate for the purposes of
setting a balanced budget. The projected level of reserves sits within a
reasonable range when assessed against the Council’s current risk profile
and service volatility. However, reserves remain relatively shallow in
historical context and are vulnerable to renewed
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