15

APHA's surveillance activities are inefficient and not risk-based, requiring multi-year reform.

Conclusion
APHA pointed out that its current surveillance activities are not risk-based or efficient, which results in APHA returning to a location on a regular basis even though it finds no issues. APHA is starting work to move to a more risk- based, intelligence-led surveillance regime and to design its management information to support this. APHA stated that this is not a quick fix and that it will take several years to complete the work.18
Government Response

A response document is linked to this report, dated 19 January 2026. Response attribution to this conclusion has not been verified. Read the response document.

Addressee Bodies
HM Treasury
Timeline
Recommendation age 0.9 yr
Report published 05 Nov 2025