General
The council is required to provide information on fraud arrangements, etc. in response to the annual request from the external auditors (Ernst & Young LLP), relating to the risks of, identification of and responses to fraud (relevant to ISA 240 - 'The Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements').
Various publications and briefings on fraud are held by the council (e.g. from central government, CIPFA, etc.) and the guidance and recommendations in these documents has been used as a basis for counter-fraud work by the council.
The council is committed to the prevention, detection and investigation of fraud and corruption. It is expected that all those who work for, serve or deal with the council will act in a fair and honest way.
The council has a specific Anti-Fraud, Corruption & Bribery Policy, including the requirements of the Bribery Act 2010, which was reviewed and updated in 2024 (and there are other policies and procedures that support and promote this). The council's Whistleblowing Policy (in respect of the Public Interest Disclosure Act 1998) was also reviewed and updated in 2025 and both updated policies were brought to the attention of all staff.
The council's internal audit service is now provided by the Southern Internal Audit Partnership (SIAP), and any specific fraud concerns would be referred to them for investigation. They also completed a review of the council's fraud framework (including the policies mentioned above) in 2023 and recommendations for improvement (including review and update of the various policies) have been progressed by senior management.
The Fighting Fraud & Corruption Locally strategy recommended that councils publicise the risks of fraud and encourage public response. Information on the key fraud risk areas facing the council and contact numbers for members of the public to report suspected fraud cases / concerns is set up as a 'Fraud' area on the council's web site and the housing fraud figures for 2024/25 (as shown below) have recently been published in the 'Our latest news' section of the council's website. A separate report on housing tenancy fraud is also provided to Members of the A&GC.
No fraud and / or corruption investigations have been carried out during the year in respect of members, under the Code of Conduct.
Benefits investigations
Until December 2015, the council had a small, dedicated benefits investigations team handling benefit-related fraud and investigations. Under the Welfare Reform Act 2012, benefits investigations were centralised into a 'Single Fraud Investigation Service' operated under the control of the DWP, although the council is still required to provide data to support DWP investigations. Members of the public are still encouraged to report suspected incidents of fraud via the National Benefit Fraud Hotline or through a link to the appropriate www.gov.uk pages on the council's website.
Housing tenancy
As advised in past reports, housing tenancy fraud is an area of significant concern to the government, and this is now a criminal offence under the Prevention of Social Housing Fraud Act 2013.
The council has 3445 properties in its social housing stock and there is a dedicated fraud investigation & enforcement officer post covering Housing. In addition to investigating active fraud leads, the investigator's remit includes prevention - working with other areas of housing in respect of:
- the process for verifying Right To Buy entitlement to purchase council properties.
- exchange and succession requests.
- non-occupation.
- abandonment.
- illegal sub-letting.
(Prevention of housing tenancy fraud allows the placement of new tenants from the Housing Register and potentially reduces emergency B&B costs).
In 2024/25 the fraud investigation & enforcement officer advises there were:
- 331 referrals received.
- 19 properties recovered and returned to the council's housing stock.
- 12 mutual exchange applications refused.
- 6 succession applications refused.
- 8 right to buy application refused.
- £31,737 of Housing Benefit and Council Tax Reduction Scheme reclaimed.
This has produced an estimated notional financial saving to the council of c. £4.185M. (The government currently estimates that cases of prevented social housing tenancy fraud are valued at £93,000 per property, based on an average four-year fraudulent tenancy and an estimate of the duration that the fraud may have continued undetected).
Other investigations
Other than the two above areas, all other fraud work is the responsibility of Internal Audit (except for any electoral fraud issues, which are handled by the Returning Officer / Police).
National Fraud Initiative
The council is a mandatory participant in the National Fraud Initiative (NFI), which is now part of the data and intelligence service within the Public Sector Fraud Authority (PSFA) launched in 2022. (The NFI was previously operated by the Cabinet Office). This is a data matching exercise that involves comparing records held by one body against other computer records held by the same or another body to see how far they match. An example would be comparing the council's Housing Benefit claimants with payroll and pension information recorded by the DWP and other participants.
In December 2024, Council Tax and Electoral Roll data was again provided for annual Council Tax single person discount (SPD) entitlement checking and the match reports received. In addition, the council's Revenues section has an ongoing a rolling review of accounts claiming SPD. Where queries have been raised and no satisfactory response received from the account holder, the SPD entitlement has been removed and the account re-billed, including backdating where appropriate. Review of the NFI reports progressed taking account of this with any further queries on entitlement to SPD referred to the Revenues section.
From review of the NFI matches:
- Of the accounts referred to Revenues for review, 95 accounts were rebilled, resulting in additional billing of c.£47k for 2024/25 and earlier, and then c.£50k for full billing in 2025/26.
- 49 accounts had already been identified by Revenues and been rebilled with additional billing of c.£28k for 2024/25 and earlier and then c.£26k for full billing in 2025/26.
(There will also be some additional rebilling for accounts not reported by the NFI, but already identified under the ongoing rolling review. It should be noted that the council only retains a percentage of the amount billed and some of the rebilling may be reversed if evidence of entitlement is provided e.g. for a student in full-time education).
Other revenues activity
The council's revenues section also undertakes a number of other checks in order to reduce the risk of fraud in respect of the eligibility for Council Tax and Non-Domestic Rates (NDR) exemption or reduction. These include:-
- inspection of empty business rated properties.
- review of mandatory and discretionary NDR discounts.
- review of entitlement to Council Tax exemptions and other discounts.
- inspection of residential properties that have been empty for more than 2 years. (From April 2025 the council has taken the decision to charge Council Tax on empty properties after 1 year of being empty).
- contact by the empty homes officer with homeowners where the property has been empty for 6-18 months.
In respect of the last two points, a further 172 properties have been brought back into occupation and the 'empty' status removed in 2024/25 through the direct intervention of the empty homes officer which has increased the council's New Homes Bonus grant income and recommenced billing of Council Tax which had been suspended while empty. This is also reported to members in Corporate Plan indicator CP22. (It should be noted that New Homes Bonus is to cease in 2026/27).