The Department had to design and implemented the schemes at speed to ensure they were in place for winter 2022–23. The Department took three weeks to implement the EPG and two months for the EBRS. At the start of the schemes, the Department assessed that the risk of fraud and error for both the EPG and EBRS was high and that the potential financial impact from the risks materialising would be high given the scale of the schemes. The risks stemmed from the untested nature of the schemes’ design, and the pace of delivery meant there could be insufficient checks on errors in claims and payments as well as lack of capacity and capability within government to perform them. In autumn 2022, the Department for Business Energy and Industrial Strategy (BEIS) sought two Ministerial Directions about the schemes. In seeking these directions, BEIS’s Accounting Officer considered the four accounting officer tests set out in HM Treasury’s Managing Public Money. BEIS’ Accounting Officer acknowledged the need for government support while recognising the “inevitable challenges in assessing and implementing [interventions] of this scale at speed” and that the EPG, AFP and EBRS pose risks and present “a very large exposure of public money”.35 We asked the former Permanent Secretary about the grounds for the Ministerial Directions. They told us that one of the reasons for seeking a Ministerial Direction was because they could not sign-off to say that all the anti- fraud measures were fully in place at the time. They explained that since the Ministerial Directions, the risk had “very much decreased”.36