The Department did not complete a full fraud risk assessment before ECO4 was implemented in 2022. This became a mandatory requirement in Managing Public Money for any new major area of spend in March 2022, but it would still have been considered good practice at the time.77 The Department clarified that it had completed an initial fraud impact assessment during the ECO4 policy stage, but accepted that it had not done sufficient preparation and had initially failed to understand some of the scheme’s exposure to fraud. The Department confirmed that the fraud risk assessment had since been completed and was being actively managed, with all risks clearly allocated to owners as of October 2025.78