Testing the Devolution Guarantee

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Pilot proposal. Published 18 October 2026. No participating authority or funding agreement has been secured.

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Civil Liberties Action | Proposal for discussion with Greater Manchester | Version 1.0 | 18 October 2026

1 The proposed pilot

CLA proposes a six-month test of the Devolution Guarantee within one existing adult-skills programme. The practical question is whether people can understand who is responsible, see how money and decisions are connected, influence choices that remain open and obtain an appropriate response when something goes wrong.

Greater Manchester is the proposed starting point because it already exercises adult education functions and publishes relevant commissioning decisions. No partnership, access agreement, funding commitment or endorsement has been secured. We are seeking an initial discussion with the responsible skills and governance officers, followed by a written decision on whether the proposal is useful and feasible.

The pilot would add a public responsibility statement, an accessible decision record, a defined route for learner input and a record of scrutiny and remedies to one programme. It would use existing lawful decision-making arrangements. Changes to contracts, funding, data access or complaints procedures would require the authority’s own approval.

2 Choose a programme that can be examined fairly

The authority and CLA should identify a programme with a clear commissioning boundary, a published decision, accessible funding and outcome data, and enough time remaining for a six-month review. Include at least one meaningful choice that residents or learners can still influence. A programme whose important decisions are already fixed can still support a navigation study, but offers a weaker test of participation.

The programme should have a named accountable executive, operational lead, finance contact and complaints contact. Statutory finance and monitoring officers should confirm the proposed arrangements within their responsibilities. A scrutiny committee should decide how it will receive and follow up the findings. CLA should name its research lead and independent reviewer before the test begins.

Confirm the applicable 2026/27 local adult-skills rules, signed funding agreement, provider obligations and data arrangements. National non-devolved ASF rules cannot simply be adopted as the local operating rules. The legal note should address the amended 2009 Act, the 2026 Act and any continuing relevant instruments. [F1, L1, L2]

3 What the authority would publish

The responsibility statement should name the decision-maker, explain the legal and financial boundary of the programme and distinguish decisions taken by the authority from those taken by a provider or another public body. It should identify who will answer questions and give an equivalent telephone or paper route.

The funding statement should reconcile the agreed programme budget with provider commitments and continuing learners. It should identify the source and permitted use of learner support, administration, evaluation and contingency provision. CLA’s earlier illustrative budget is not an estimate of Greater Manchester’s actual programme and must not be carried into the pilot as though it were.

The participation statement should identify an upcoming choice, the options that remain possible and the constraints. Learners should be able to contribute through accessible routes. The authority should then publish its response and reasons. A learner group would advise on the choice unless a separate lawful delegation expressly provides otherwise.

The complaints guide should explain the relevant provider and authority procedures and any applicable external route. Each route needs its own scope and timetable. The guide should be tested with residents before use. The pilot would keep an aggregate record of response time, extensions and agreed remedies, without transferring personal complaint files to CLA.

4 Establish the baseline and review dates

Before changes are introduced, record the documents and routes currently available, a small set of navigation results, outstanding scrutiny actions and the staff time spent on reporting and administering the programme. Agree the definitions and collection burden with the authority and providers. Where historical data cannot be reconstructed reliably, state that gap and begin prospective recording.

At three months, check whether the published commitments have been implemented and whether any access or delivery problem requires correction. At six months, assess clarity of responsibility, completion of scrutiny actions, resident navigation, reporting effort and complaint handling. Use the same definitions and distinguish changes to the programme from changes to the information about it.

Programme outcomes should include participation, completion and progression where appropriate, with clear cohorts and follow-up periods. Report unknown progression separately. Six months may be too short for a mature progression measure. A small rise or fall should not be presented as proof of an effect caused by the Guarantee. An impact study would require a separate design. [M1]

5 Agree how problems will be handled

The authority should rehearse a provider failure, interrupted payments and a serious learner-rights concern before launch. Each exercise should identify who can act, which records are required, how learners will be contacted and how continuing provision will be funded. Record gaps and close them before the affected part of the pilot begins.

An urgent threat to safety, rights or continuity should be escalated immediately through the applicable authority process. A financial forecast beyond available resources should trigger a formal recovery decision. A pattern of missed complaint deadlines should lead to examination of the affected cases and the practical capacity to resolve them. These are proposed management responses; they do not create statutory intervention powers.

Pausing the evaluation must not suspend a learner’s service or legal remedy. Any proposed change to provision requires the authority’s own decision and a continuity plan. Publish the reason for a pause and the conditions for resuming the test. The authority and CLA should also agree how unresolved disagreement about the findings will be recorded.

6 Resources and agreement

The scoping discussion should produce an itemised estimate of authority, provider and CLA staff time, independent review, participant support, accessible publication and evaluation costs. No cash request or paid commission is made in this proposal. An approved budget and lawful funding source are prerequisites for any commitment.

A short written agreement should identify the selected programme, named responsibilities, access to public and aggregate data, publication rights, factual-review process, dates, costs and exit arrangements. CLA must be free to publish a fair account of the result, including a result that does not support the campaign’s expectations. Confidentiality should protect genuinely confidential material and personal data without giving either party control over the findings.

The immediate request is for the authority to identify the appropriate programme lead and say whether it would consider a scoping meeting. If the proposal is unsuitable, a brief explanation would still help us refine the Guarantee. We would not describe a discussion or an acknowledgement as agreement to a pilot.

References

  1. [F1] Adult skills fund: funding and performance management rules 2026 to 2027. Updated 14 September 2026; Introduction, What is new, Purpose, Who we fund and Annex B.
  2. [L1] English Devolution and Community Empowerment Act 2026. Section 108(1)(b) and (3)(r); section 32. Education provisions commenced at Royal Assent on 29 April 2026. XML text inspected.
  3. [L2] English Devolution and Community Empowerment Act 2026 Schedule 13. Part 1, especially paragraphs 2, 6, 9 and 11; inserted sections 114A and 120B of the 2009 Act. XML text inspected.
  4. [M1] HM Treasury Magenta Book. Evaluation design, theory of change and attribution. HTML inspected on 18 October 2026.

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