The Department does not have a reliable estimate of its fraud losses or the information it needs to effectively prioritise counter-fraud activity. While it has reported that it may be exposed to up to £1.5 billion of fraud losses each year, this figure is derived from external benchmarks rather than a robust assessment of the Department’s own fraud risks and controls. The Department itself describes the estimate as an academic construct. Without a credible understanding of the scale and nature of its potential losses, the Department cannot make informed decisions about where to focus its counter-fraud effort. During our evidence session it was unable to say when it would have a reliable estimate, instead pointing to its counter-fraud strategy due in September 2026 as setting out future plans. The Department later told us that it expects work to develop a more reliable estimate was likely to take about a year. Alongside this, the Department’s numerous fraud risk registers do not quantify potential fraud losses, limiting their usefulness as a management tool. The Department accepts that it has not made sufficiently active use of them to direct resources to the areas of highest risk. It told us that it intends to include estimated fraud values in its risk registers during 2026–27 and that it is engaging with the NHS Counter Fraud Authority, which publishes a transparent, risk-based estimate of its fraud exposure. But these steps remain prospective and underline that the Department is operating without the basic information it needs to effectively manage a significant and well-recognised risk to public money. 4 recommendation The Department should work with the Public Sector Fraud Authority and NHS Counter Fraud Authority to develop a more robust estimate of its fraud losses. The Department should set out its plan to improve its estimate in its 2025–26 annual report. From 2026–27 it should publish an increasingly robust estimate in its annual reports, based on a growing