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16 September 2026
The immediate position is now clearer. Decisions affecting Essex, Southend-on-Sea and Thurrock; Hampshire, the Isle of Wight, Portsmouth and Southampton; Norfolk; and Suffolk have been withdrawn. Decisions taken in July are under review, as are the two outstanding areas awaiting decisions. Surrey is unaffected, and the new East and West Surrey councils remain due to go live in April 2027. Local elections elsewhere will proceed in May 2027 on existing council boundaries.
But the more important question for councils is what the review is really reviewing.
The Government has referred both to the legal robustness of the process and to whether the programme remains aligned with its wider plans to “rewire the state”. That suggests two distinct strands.
The first is procedural: whether previous decisions were reached through a legally robust process and whether the route to future decisions needs to change. The second is strategic: whether the structures and geography previously selected remain consistent with the Government’s developing approach to devolution and the relationship between local councils and strategic authorities.
Councils should therefore avoid treating the pause as simply an extension of the existing timetable. The review may ultimately affect not only when LGR proceeds, but also the assumptions on which proposals were prepared.
Affected councils will need to distinguish carefully between implementing a particular decision and undertaking work that remains necessary or valuable independently of that decision.
Steps designed specifically to establish a selected successor structure may need to cease. However, that does not necessarily mean abandoning service improvement, organisational resilience or the factual work needed to understand the existing councils.
The dividing line will not always be obvious. A contract-mapping exercise may have started as part of an LGR programme but may also identify unmanaged liabilities and opportunities for rationalisation. Work on digital systems may have been intended to support a successor authority but may still address existing resilience or interoperability issues.
The purpose of the work, its current scope and the legal basis for continuing to spend should therefore be revisited and recorded.
Councils should now think in terms of maintaining strategic optionality.
That means separating work which assumes a particular geography or vesting date from work capable of supporting several outcomes. Option appraisals should identify which conclusions remain sound if boundaries, timescales or the role of strategic authorities change.
Authorities should also preserve the evidence assembled to date. Data rooms, asset schedules, contract registers, workforce analysis and financial modelling may all remain useful, but only if they are kept current and their assumptions clearly recorded.
Programme knowledge is equally important. Allowing established teams and governance arrangements to disappear entirely may leave councils rebuilding capacity when the review concludes. Conversely, retaining every workstream unchanged may be difficult to justify. A smaller core team, revised terms of reference and periodic decision points may provide a more proportionate approach.
The pause does not displace ordinary public law and governance requirements. Decisions to continue, scale back or stop work may involve contractual liabilities, staffing consequences and further expenditure of public money.
Authorities should identify the correct decision-maker, obtain appropriate financial and legal input, and maintain a clear audit trail. They should also be explicit about which assumptions are facts, which remain government policy, and which are local planning scenarios.
This is particularly important where a decision could constrain a future administration or make one eventual LGR model materially more difficult to implement.
There is still substantial value in “no regrets” work. Councils can improve their understanding of contracts, land, assets, liabilities, data, systems and service dependencies. They can map interests in companies, LLPs and joint ventures, together with loans, guarantees, shareholder rights and change-of-control provisions.
This is not merely preparatory work for reorganisation. It is part of responsible corporate management and may reveal risks requiring attention regardless of what happens next.
The developing LGA and MHCLG FAQs provide an important source of clarification. The more strategic task for councils, however, is to use the pause to protect the value of work already undertaken, challenge assumptions that may no longer hold and retain the ability to respond to more than one possible outcome.
The aim should not simply be to remain busy during the pause. It should be to emerge from it better informed, more resilient and ready to move in whichever direction the Government’s review requires.
This article is for general awareness only and does not constitute legal or professional advice.
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This article is for general awareness only and does not constitute legal or professional advice. The law may have changed since this page was first published.
