Recommendation RHI-40: Declaration of Interests
From The Report of the Independent Public Inquiry into the Non-Domestic Renewable Heat Incentive (RHI) Scheme, published 13 March 2020.
Recommendation
Ministers, Special Advisers and officials in Northern Ireland government Departments should declare their interests annually in writing. When any conflict of interest arises during the course of government business each individual should understand that he/she has an obligation formally to declare that conflict and ensure that it has been recorded. Departments, for their part, must have and implement clear policies and procedures so that all those concerned know what they have to do and when. The relevant existing policies and practices should be tightened up and rigorously implemented to ensure they are consistent with best practice. Conflicts of Interest guidance published by the Northern Ireland Audit Office in 2015 is a good baseline. We further recommend that the registers of interests be made public.
In brief (written by this site)
In March 2024, the Department of Finance reported that implementation was in progress, stating that ongoing compliance monitoring is a matter for departments and that the option of a one-off audit by NICS Internal Audit would be raised within 24 months of the next Executive being formed (Department of Finance, Mar 2024). The Northern Ireland Audit Office assessed the recommendation as implemented in October 2024 (Northern Ireland Audit Office, Oct 2024). While acknowledging that the department will consider an audit alongside other priorities, it emphasised that a one-off review across departments remains important to provide confidence that the system works as envisaged (Northern Ireland Audit Office, Oct 2024).
AI-generated summary of the record on this page, checked by a second model and automatic checks, 26 Sep 2026. The record below is the sources' own words.
About this summary
This recommendation applies across many organisations. The record reflects central policy activity; adoption in individual organisations may vary.
Government response
These recommendations can be accepted in full, with the exception of the consideration of an independent mechanism to assess special advisers’ compliance with the Code of Conduct.
They have been addressed through work to date, including:
• revisions to the Ministerial Code of Conduct, Code of Conduct for Special Advisers and NICS Code of Ethics, and the introduction of new Guidance for Ministers;
• the publication of new enforcement arrangements for ministerial standards of behaviour;
• agreement on the development of a multi-year outcomes-focussed Programme for Government, aligned with the Budget, including stakeholder engagement and consultation;
• departmental induction and briefing for Ministers on the return of the Executive, and Executive away-days;
• the strengthening of Private Offices including the higher grading of the Private Secretary and Assistant Private Secretary roles;
• identification of the team where matters of policy in respect of Special Advisers are to be dealt with.
Further work is required to:
• deliver induction programmes for Ministers and for special advisers;
• arrange for publication of relevant interests of civil servants.
How this response relates to the recommendation
Site note: These are the Northern Ireland Executive's words from Annex A, "Summary of Recommendations and Response", published on this page with the Executive Response to the RHI Inquiry Report Recommendations and Action Plan on 7 October 2021, the day the Executive agreed it. The Department of Finance publishes the response, but it is the Executive's, so the site records it under the Executive. The annex is a PDF that the publisher asks automated readers not to fetch, so the site cites the page that links it.
Site note: Annex A gives this passage once, for the recommendations under its heading "MINISTERS AND SPECIAL ADVISERS": recommendations 5, 6, 7, 25, 37, 39, 40, 41, 42 and 43. It is the Executive's response to the group, not to this recommendation alone.
Delivery
Department of Finance says in progress (14 March 2024)
Ongoing monitoring of compliance with the relevant processes is a matter for departments.
The option of a one-off audit by NICS Internal Audit of the declarations of interest process implemented by departments will be raised within 24 months of the next Executive being formed.
From: Implementation of the Recommendations of the RHI Inquiry (publication page for three documents)
Site note: This page publishes three monitoring tables: the Department of Finance's of 1 September 2023 and 14 March 2024, and the Executive's table of 19 February 2025 of commitments on the remaining recommendations. None of the three lists every recommendation. The row carries the table's own cell for this recommendation: the "Updates" column, or where that is empty in 2023 the "Status of further work" column, and in 2025 the "Commitment" column. The tables are PDFs that the publisher asks automated readers not to fetch, so the site cites the page that links them.
Earlier statement on delivery (1)
Department of Finance (1 September 2023)
Ongoing monitoring of compliance with the relevant processes is a matter for departments.
GIAFIS will be requested to conduct a one-off audit of the declarations of interest process implemented by departments within 24 months of the next Executive being formed.
From: Implementation of the Recommendations of the RHI Inquiry (publication page for three documents)
Site note: This page publishes three monitoring tables: the Department of Finance's of 1 September 2023 and 14 March 2024, and the Executive's table of 19 February 2025 of commitments on the remaining recommendations. None of the three lists every recommendation. The row carries the table's own cell for this recommendation: the "Updates" column, or where that is empty in 2023 the "Status of further work" column, and in 2025 the "Commitment" column. The tables are PDFs that the publisher asks automated readers not to fetch, so the site cites the page that links them.
What other bodies have found
In their own words. These do not change the delivery statement above.
NI Audit Office (15 October 2024)
Implemented.
Whilst acknowledging what the Department has told us, that an audit of the declarations of interest process across departments will need to be considered alongside other priorities, we would again emphasise the importance of our recommendation, that a one-off audit by NICS Internal Audit of the declarations of interest process would provide some confidence that the system is working as envisaged.
Site note: This is the Northern Ireland Audit Office's assessment, from Appendix 4 of its second report on the Inquiry's recommendations (15 October 2024), the column "2024 NIAO Assessment". The Audit Office monitors implementation at the Inquiry's request; its assessment is shown beside the Executive's own account and does not set the recommendation's status.
Site note: The report assesses this recommendation in 4 parts and gives no assessment of the whole; the row carries its assessment of the first part.
Source
Responsible bodies
Themes and tags
Who has spoken
- Northern Ireland Executive
Response - Department of Finance
Delivery statement - NI Audit Office
Finding