We continue with exploratory work that will help shape what the FOI Network will become, and how it will best serve specific types of those who use Freedom Of Information. Last week, in our second workshop of three, we convened journalists and specialist users to help us understand what the barriers are to their use of FOI, and how the Network will be best positioned to help.

More than 20 people joined us, from a range of organisations and specialities. 

A group brainstorming session surfaced the challenges and obstacles that attendees face when using FOI in their work. From these, we pulled out four priority themes; then we further discussed how best to mitigate these challenges; and what an FOI network could do to help.

Themes and conclusions

Passive pushback

The phrase “passive pushback” describes a culture within authorities not of active hostility, but in which FOI requests are not processed promptly, and where transparency is neither celebrated nor prioritised. 

Participants talked about different kinds of delays and obstructions, and strategies they’d attempted to get around this, including formal approaches such as referring to relevant ICO decision notices, or working with lawyers so correspondence included their letterhead. 

Could an FOI Network support, incentivise or celebrate a culture of openness and compliance within authorities? The group discussed the importance of both carrots and sticks (or shame and envy), rewarding and highlighting good practice; and potentially putting out comparative FOI statistics to make performance more visible and easy to benchmark. 

Active pushback

Active pushback covers more explicitly obstructive behaviour, including the use of rules and processes to slow down the progress of a request (for example, the use of public interest exemptions which may later be reconsidered and overturned), and coordination between authorities (where the intention is rarely to ensure everyone is being correctly open, but more likely to be working against the spirit of the ‘applicant blind’ principle that is written into the FOI Act). 

Participants shared the methods they’d attempted in the face of such stonewalling, including complaints to the ICO, “meta requests” asking authorities about their coordination mechanisms, and naming and shaming authorities for obstruction. 

As a network, we can provide peer support and resources around such tactics, and useful responses. 

But there is also an important advocacy angle, where building evidence and lobbying to change ICO/OSIC enforcement strategies can be an important collective rather than individual counter to obstructive approaches. 

A State of FOI report could cover both the positive “culture of openness” stories, but also dig more into patterns in obstructive responses. 

Writing/managing good requests

One important issue that came up in conversation was that it is a skill to write and manage FOI requests well — one that takes time to learn. It requires both an understanding of when legal approaches are helpful, but also a sense of what is possible through Freedom of Information (where a focus on specific information that already exists is required). 

Building this expertise can be a problem if FOI skills are not already well embedded in your organisation, and you are starting effectively from scratch. 

Here, community and training would be helpful. As a newcomer takes time to build up accumulated wisdom, peer support and mentor programmes could be helpful in walking through concrete examples of where FOI can and can’t be helpful. 

Going beyond that, we discussed the concept of training products and services that could help support increasing specialist use. These might include a custom newsletter featuring FOI tricks and tips, not aimed at first time users, but for journalists and specialists. The network already includes several organisations and individuals who could provide such training and expertise — and a willing audience. Here, the value of the network would be in joining people up, rather than trying to do everything itself.

The role of technology was also discussed. It can help with the challenge of managing requests  — one peron mentioned (unprompted!) WhatDoTheyKnow Pro as helpful for tracking and extracting data. 

Some are using AI to help them refine their requests, and we discussed the potential ways we could make AI assistance lean more towards “sharper, easier to process” requests, and away from the problems, already observed, of for example where AI hallucinates ICO notices and inserts them into correspondence. Here a network could help disseminate a ‘skill’ to bring more specialist knowledge towards shaping the AI’s actions; and a network that was also inclusive of FOI practitioners could help refine that from both sides. 

Understanding/using appeal processes

The final challenges we discussed were around understanding and using the appeal processes that are built in to the FOI system, noting that there’s a strong difference between Scottish FOI and the rest of the UK: legal appeals to OSIC are rare (and only possible on points of law). 

We again talked about the value of peer support; as well as building collections in response to common pushbacks. It was acknowledged, though, that taking things to tribunal is hard, and that one can be outgunned by the representation of the public authorities. 

Here it’s important that network activity is not just support for individuals, but lobbying and campaigning for improvements to the overall appeal system. 

This might be through pressing for improved data and information such as ICO timescales, and the tribunal returning to publishing current and upcoming cases; but also through lobbying for greater funding for regulators to be able to run an effective and timely system of appeal. 

Takeaways

Thanks to all who took part in the conversation, which has helped shape our understanding of what is useful activity to support journalists and specialist users.

Practical peer support for those in smaller organisations might be especially important — but dealing properly with the issues raised also involves wider campaigning activity around making sure the overall system is functional to be able to engage with. 

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In our third workshop, we move to a focus on those working in public authorities, where we want to explore more of these questions around supporting a culture of openness, and also our common interest in improving the quality and clarity of requests. If you are an Information Officer or practitioner, please do join.

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Image: GuerillaBuzz

Liz Vango-Smith is Sustainability and Climate Change Officer at Hart District Council, where she manages the climate change programme, helping to meet their carbon reduction targets both internally, and across the district. She recently took the time to speak to us about the part that the Council Climate Action Scorecards play in her work.

Liz explained how the Scorecards are part of a wider push toward staff engagement in climate action, right across the council: “We’ve been integrating climate messaging into team briefings, running service area climate workshops, and offering carbon literacy training.

“And the Scorecards have also informed discussions at the Officers’ Working Group, a cross-council meeting with representatives from across the different service areas, including procurement, estate management, planning, waste services, street care and grounds maintenance, as well as community engagement and the natural environment.

“The combination of all of these things has helped more officers recognise they have direct roles in supporting delivery of our climate action plan.”

So where, specifically, have the Scorecards helped? “We’ve used them to highlight areas where we could improve our scores, and to focus climate action where it may not be a current focus. The published scores help provide a little more weighting to encouraging collaborative action with colleagues, as they create a level of accountability across the whole organisation to play their part.

“Of course, we already monitor and report climate action, but the specific details in the scoring have helped us identify additional ways in which we can measure progress.”

Liz says that the Scorecards have helped them focus on messaging, as well: “They’re a helpful tool to provide confidence to stakeholders that we’re making meaningful progress in taking climate action — and we’ve also used them to help improve the way we inform the public about our progress, as it highlighted that perhaps we don’t always promote some of the good work we do.

“So we’ve now included reference to the Scorecards on the council’s website, to show the public we are improving our scores and to encourage them to find out more.”
Finally, there’s one other big, positive change where the Scorecards played a part:

“They brought the conversation back to our energy supply, and we realised we still didn’t have a 100% renewable tariff. We took action and now we do. Not only that, but a ‘deep green’ tariff that directly supports new, sustainable generation.”

Many thanks to Liz for sharing the impacts that the Scorecards have had on Hart Council and beyond. The Scorecards are a joint project between Climate Emergency UK and mySociety.

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Image: Mr Ignavy (CC by/sa-2.0)

Have you visited sewagemap.co.uk? If you care about your local rivers, lakes and seas, you might want to take a look at this very graphic display of where sewage is being discharged across England.

If you’re wondering which sense of ‘graphic’ we mean, well, it’s both: first, it’s easy to see the information at a glance. And second, if there’s an active discharge right now, you’ll see an unapologetic poo emoji hovering above your postcode, alongside a brown river to show how the sewage will spread.

So this is a very useful site that makes it easy to understand the current picture around sewage discharges in your area. But if you’re hoping to understand how the situation is changing, you’re out of luck. You can’t see historic data, and that’s because — with the exception of Thames Water — the water companies don’t make it publicly available.

Infuriating, right? Good! Because, thanks to incorporation of our WriteToThem service into the site’s workflow, you can email your MP and let them know why you think this data is important.

And it’s working — we became aware of the site because of the number of messages it refers through to WriteToThem. Curious to know more, we spoke to Alex Lipp, one of the site’s two creators, to find out how it had come about, and what it has achieved.

“It’s kind of a pet project,” Alex explains. “One day I was was playing around and I noticed there was live sewage data being published by water companies. 

“Now, the data itself might be quite dull, but I realised that if you could make the link between sewage stats and the rivers that people know and love, they would be more likely to take an interest. 

“I work in fresh water science so I could handle the technical side of things; and Johnny, a friend from uni, works in geodata visualisation: he did the design. The set-up isn’t exactly high-tech: it’s literally running off my old laptop, plugged into an Ethernet port at work. 

“But it works — it performs well in search engines, and it had 350,000 views last year. We just want to present what would normally be very boring environmental data in a way that engages and makes sense to regular people. Existing sites only showed the points of discharge. It just seemed really obvious to me that what people wanted was information about impacted rivers, which was not included in the other visualisations at all. So I added it in!”

And that historic data would be useful too, right, so people could see whether things were improving or declining?

“Yes! Perhaps surprisingly, Thames Water are much better than other providers, when it comes to data transparency. They published data before all the others, and they have a live API you can query. 

“The other water companies make it difficult to query historical data – you generally have to send them an EIR request, because the law technically only requires them to share live data. It’s an oversight of the 2021 Environment Act that water companies aren’t required to publish historical data. So we note on the site where a company doesn’t make it available, and that’s the prompt for people to email their MP and explain why it’s needed.”

Why does the site only cover England? “The Environment Act doesn’t apply to Scotland or Wales – so that’s even more complicated. In Scotland and Wales, water companies are nationalised. They voluntarily publish similar data, but aren’t required to, and it’s in a different format.”

And so – with the site encouraging users to email their MPs, what makes for an effective message? Alex reckons it’s two things:

“Personal stories, and local stories. Just at a fundamental level it feels wrong for sewage to be going into rivers”. So, if you can explain what it means to you — maybe you’d like to take your kids swimming in that river, or you remember it being a clean place to play when you were a kid yourself? “Yes. It’s actually an issue most people can agree on, and there’s strong cross-party support.

“And I think this is a mutable thing that could be fixed…well, lets see if that’s true!”

What impacts has Alex seen so far? “We have a lot of users, and I get a lot of contact from members of the public — anglers, swimmers, campaign groups — who use the data we present and our visualisations to help gauge whether the rivers are safe. 

“I’m also fairly confident (but can’t directly prove) that MPs are using the site to get data for discussions that have taken place in Parliament, and are recorded in Hansard. And, most recently, the press team for the recent Dirty Business documentary used the site to get information for their campaign. 

“So, we have in general had a distributed impact via widespread use. I confidently think we have contributed to the wider discussion, applying pressure to fix the issue of sewage spills.”

We very much hope so! If you agree that data is the key to understanding the sewage spills issue, and being able to do something about it, head over to sewagemap.co.uk, check out your own postcode and then drop a line to your MP (you’ll find the link in the ‘discharge history’ tab when you click on an icon) to let them know.

LLMs can increase demand on public systems by removing the friction that previously limited access. One potential result of this is new forms of unconsidered rationing that recreate that friction. Instead, we should move away from zero sum systems and aim for technical and policy approaches that turn unscalable private benefits into efficient collective ones. 

Many kinds of citizen-driven interactions with the public sector are rationed through friction: fewer people engage in them than might do otherwise, because they feel the process is time-consuming or requires expertise. We can see examples of this in planning objections, correspondence with elected representatives, FOI requests and consultation responses. LLM technologies can lower the time or expertise required and also prompt people to engage in the processes in the first place: “Would you like me to draft a complaint about this?”

Systematic impacts

This reduced friction may be good for individuals, but the resulting increase in engagement can overwhelm the system itself. In response, it may slow down, collapse, or adopt new means of rationing or prioritising access. We can see indications of this across different kinds of interactions: journalist Martin Rosenbaum has identified an upward trend across public sector complaints organisations, and concerns are being raised across sectors about AI’s contribution to growth in volumes. 

So how should organisations that handle public submissions respond in an informed way? Here’s an approach to thinking about the problem. We can divide these interactions into three types:

• Private benefit – when an interaction has a benefit almost exclusively to the requester, either competitively (eg a grant or job application), or non-competitively (eg an application for a state benefit).
• Collective benefit – when an interaction has a benefit to the requester, and also to wider society (eg a public FOI request, reporting a pothole). 
• Zero sum interaction – when an interaction success for one person is a failure for another (eg planning). 

Private benefits

Some public services fall clearly in the first category: they are unavoidably a collection of private interactions. For these, there might be improved efficiencies to be found in delivery at scale but, particularly for non-competitive benefits, these are also likely to eventually run into decisions either about increasing provision (assuming a higher level of claims from those entitled going forward), or new forms of rationing.

As stands, AI inputs can both improve the efficiency of systems through sharper, more complete initial submissions, but can also make more verbose and complex submissions that cite non-existent law. To prioritise the former over the latter, systems can explore triage approaches that enforce or encourage the qualities that make input valuable: clarity, accuracy and concision. 

When running into real limits, it is important to be clear about the criteria you want to ration on, and that they are in line with the overall purpose of the system, rather than implicitly prioritising those with greater resources.  In their FOI complaints system, the ICO is using public benefit as a criteria for prioritisation. The British Academy uses partial randomisation above a scoring cutoff to ration randomly rather than requiring additional work (on both sides) to further differentiate.

Collective benefits

A bigger win is, where possible, to transform private benefits into collective benefits.  In these cases, reduced friction is self-regulating because spillover benefits from an individual’s case help reduce demand from others : the private benefit person B is looking for has already been provided by person A’s interaction. 

One of the key ways mySociety’s services help people is to harness the self-interest of individual users for collective benefits. Every public request made on WhatDoTheyKnow also adds to the pool of public knowledge accessible on the internet, reducing the need for duplicate requests (with a similar logic to reducing duplicate reports on FixMyStreet). This means we can effectively lower the bar to access while improving overall efficiency of the system. 

We come to this from a technology lens, but the same principles apply from an institutional-design approach. For instance, if MPs’ casework or complaints are  increasing, you want to shift towards more systematic rather than individual benefits from casework. This looks like support for better collective learning, and an improved ombudsman to support collective rather than individual fixes. This kind of approach works best where good statistics are collected at a system level to help identify what collective changes are needed: tracking the overall level of demand, level of demand to different parts of the system and nature of the demand, ie what are people asking for.

Zero sum systems

The biggest shift needed is in reforming zero-sum systems, where there is currently an incentive for both sides to escalate the volume. Reduced friction here just raises costs for all concerned rather than giving increased benefits to anyone. Individual use of AI to create submissions is individually enabling in these cases, but not collectively. So, in the words of the 1980s classic film War Games, “the only winning move is not to play”. The real innovation is in solutions that open up new, and more effective, ways of working out what everyone can live with, rather than recreating rationing through new means. For instance, rather than adversarial AI planning objection generators, we could aim for a collaborative planning system that through improved communication and coordination lowers costs and removes incentives to volumes of engagement. 

Red flags for zero sum interactions are when volume is implicitly being used as a proxy for strength of feeling, or popularity of a particular viewpoint, because its value as a signal is going to become increasingly degraded as AI use increases.   

Systems work better when the benefits are collective rather than atomised

Mass adoption of AI removes one set of bottlenecks, but this can create capacity challenges for public systems. Previous waves of civic technology have built on reduced costs of storing and sharing information to build systems that help share the benefits of people’s work and lower the barriers to entry.

The current wave of AI chatbots cut against this, encouraging atomised approaches, rather than collective ones. We need to explore technical and policy approaches that help systems better achieve their purpose, without giving up on the idea of lowering barriers to entry. We can do this both by exploring how the technological features of AI tools can be bent towards collective gains, and moving away from systems that incentivise these approaches. 

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Image: Engin Akyurt

The FOI Network is an informal coalition of civil society organisations, journalists and academics with an interest in Freedom of Information, convened by mySociety and State of the Future. Last week, we held our first meet-up, in the shape of an online workshop, to discuss and prioritise the ways in which we might strengthen and defend the right to information in the UK. With potential threats rumbling on the horizon, it was a timely conversation.

Attendees came from a range of organisations and specialities. We had a group brainstorming session to identify firstly, opportunities to strengthen or expand FOI; and secondly, key threats and challenges.

From these, we pulled out four themes, which we discussed from the angle of which activities would bring the most impact for the effort expended.

Thematic groupings

The four topics discussed were:

• The expansion of FOI to currently uncovered bodies/sectors
• AI as an opportunity and challenge, and proactive / better publication
• Practical difficulties/support for FOI within public bodies
• The government’s opposition/lukewarm attitude towards existing/greater transparency

FOI expansion

As  FOI’s reach is expanded, so is its utility to new groups, who would benefit from the Act in different ways. This is an approach that can benefit communities who have historically had low levels of power.

Expanding the FOI Act to new authorities would make possible new avenues of research and enquiry, providing access to useful data where it is not currently available. This includes important areas such as housing; or private contractors to government, where the case for increased transparency is easy to make.

We’re fortunate that we can look to Scotland, where Registered Social Landlords are subject to FOI requests, as an example: there is already a good evidence base for successful expansion. Equally, good arguments for expansion could be made by showing the types of essential questions that cannot currently be answered under the regime as it stands.

AI as opportunity and challenge, and proactive / better publication

In this area, the group decided that there are no highly effective actions that would also be easy to implement. Instead, we would be looking at a range of sensible small interventions around better guidance, training research, and more intensive technical work around proactive disclosure and unlocking the benefits of public data.

There is a wider problem around AI potentially overwhelming appeal mechanisms (for more on this, see the two Information Commissioners’ talks at FOI Fest). There is more to explore here, around triage methods, AI and increased volumes of both requests and appeals.

Practical difficulties/support for FOI within public bodies 

An effective FOI system requires information officers to be well-resourced and supported within their organisation.

Here, potential actions ranged from campaigns for better stats around FOI (making FOI more visible to decision-makers, as in Scotland); sharing and promoting the success stories of FOI to show the value of the work; better networking/surveys of the profession; campaigning for statutory FOI officers; and technical support on document management/search technologies. 

There was also some discussion around organisations where responding to requests pulls officers away from other work, affecting the prevailing attitudes towards FOI. The concept of statutory officers would have some bearing on this.

We will develop this segment in a further workshop, to which practitioners themselves will be invited. 

Government opposed to/has a lukewarm attitude towards transparency

A key concern is how we improve FOI, when some of the mood music coming out of government is in favour of greater restrictions. But at the same time, “government” is a wide term: while there will be some institutional reluctance to transparency, there will also be some pockets where it aligns with other stated objectives. 

We need a clearer map and understanding of these factions. We may need to be both defensive, pushing back against threats to transparency, while also building diverse institutional support. One benefit of an FOI network is that different parts of the coalition can do both at once.

From this follows a need for positive, public advocacy for the benefits of transparency, as well as a clear narrative of how it fits into wider government agendas around the redress of historic injustice, anti-corruption, value for money and so forth.

So that’s the summary of our discussion. We’ll keep you posted with progress reports from the FOI Network.

The next meet-up is about how the Network can support journalists and specialist users of FOI: if that’s of interest, sign up here.

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Image: Mark Fletcher-Brown

We’ve just started a new project exploring how improved data and training could help youth services in England – building their financial sustainability and representing their communities at a national policy level.

Working with the Social Investment Business (SIB), which coordinates the government’s Youth Investment Fund, we’ll be talking to youth organisations across the North of England between now and July, to understand what challenges they face with coordinating action, demonstrating support, and evidencing impact for fundraising.

Through a short series of interviews, workshops, and free online training sessions, we’ll find out together where there might be opportunities to build these organisations’ capacity for data analysis and engagement with public authorities.

We’ve already seen how climate and nature organisations have used the Local Intelligence Hub to identify local partners, compare approaches nationally, and prepare for conversations with their councillors and MPs. Through this project, we’ll get a chance to explore whether that same model could help organisations in the youth sector to build stronger partnerships and deliver their services more effectively.

Nick Temple, SIB CEO, said: “One of the key challenges we hear from youth organisations is how hard it can be to evidence their impact while juggling frontline delivery. This project with mySociety gives us a valuable opportunity to explore practical ways that data, insight and shared learning can support organisations to grow stronger, collaborate more effectively, and make their voices heard—building on the legacy of the Youth Investment Fund for the long term.”

We’ll be inviting current and former YIF grantees to get involved, via SIB’s network, shortly.

But if you’re a youth organisation in the wider sector and would like to find out more about the project, or how your organisation could make the most of mySociety’s other tools like TheyWorkForYou and WhatDoTheyKnow, you can still be involved – just get in touch!

In a recent blog post, we set out why proposals to reduce the Freedom of Information cost limit would reduce government transparency, without meaningfully reducing the burden on public authorities, since then the opposition to the move has grown. 

What’s the problem?

On 18 March 2026, The Financial Times reported that the government is considering lowering the cost limit for FOI (and therefore increasing the amount of FOI requests that can be rejected). The justification given for this is rising request volumes,  financial pressure on departmental budgets, and a mooted national security question (paywalled link).

What people are saying

Across our FOI network and beyond, these arguments have been widely challenged. In his initial blog post, journalist George Greenwood argues that the risks being cited are already well understood and already addressed within existing FOI exemptions. He goes further in the Times (paywalled), describing the proposals as a “democratic retreat” that would make it harder to uncover government wrongdoing and major public scandals. 

Looking at the cost argument, Jenna Corderoy’s piece for Democracy for Sale highlights how departments have spent significant sums fighting FOI requests in tribunal, often unsuccessfully. This shows that some of the highest costs of the FOI system are not just from processing requests, but are the result of  departmental decisions to resist disclosure in the first place.

Claire Miller’s #FOIFriday roundup questions whether FOI admin costs are significant in the context of overall public spending, and highlights evidence that lowering cost limits is unlikely to reduce overall workload. Instead, Claire points to the role of internal reviews, complaints, and inefficient handling as key drivers of cost, and emphasises the benefits of proactive publication and better systems.

Editorial and institutional voices have also weighed in. A Sunday Times editorial (paywalled) frames the proposals as part of a broader pattern of excessive government secrecy, warning that lowering the cost limit would create a “serious democratic deficit”. The Society of Editors has similarly warned that restricting FOI would damage press freedom and make it harder for journalists to hold power to account.

Sector-specific responses highlight the wider impact. The Committee for Academic Freedom have written that lowering the cost limit would disproportionately affect complex, investigative requests, and in a university setting transparency is already hard-won, so scrutiny efforts should be supported, not diminished. The Press Gazette has argued that reducing the cost limit would put public interest information “beyond scrutiny”.

The story has reached elected representatives too: last week local councillors in North Yorkshire raised concerns about how a possible cost limit reduction would negatively impact local government transparency.

What are the real problems, and where can solutions be found?

The current debate reflects real pressures within the system, but the response from across the FOI community and beyond is clear that restricting access to information is not the answer. 

If the aim is to reduce cost and pressure, there are better ways to do it. Efforts to reduce access to information risk introducing larger costs elsewhere, including from inefficiency, poor decision-making, and reduced public trust. Better proactive disclosure from authorities will mean fewer requests need to be made, and fewer fights at tribunal level would save the government money. 

Transparency is not a “nice to have” that can be scaled back when budgets are tight.  It is an essential component of public services that work in the public interest. Governments that think they cannot afford transparency will be surprised at the corruption and inefficiency they will need to afford in its absence.

We’ll be continuing to write and campaign on this issue, make sure you’re signed up to our mailing list if you want to be notified of any developments. 

Photo by Markus Winkler on Unsplash

Generative AI is good at solving some kinds of problems, and bad at solving others. With the rush to apply AI approaches across the public and private sector, we want to encourage people to use the right tool for the right problem. This blog post proposes a test that makes it easy to understand whether or not the applications are genuinely beneficial for the job in hand.

Generative AI has no concept of truth. It is designed to create outputs that are internally consistent, and this might or might not coincide with true things when the training data and context are well aligned. By now, we’ve all heard examples of false-positive hallucinations, where AI has asserted that something exists or was said because doing so is internally consistent with the question — but which turns out not to be true. Depending on the application, if unchecked, this can have catastrophic effects, meaning that validation of outputs is essential.

How to assess your project for AI suitability

In our recent Shifting Landscapes report, we shared a simple matrix that helps to assess how useful it is to apply an AI approach to any given problem.

It asks how hard/expensive is it currently to produce a solution without AI, and how hard/expensive is to verify that the solution is correct, with four potential outcomes:

Let’s look at each possible outcome in turn:

1. Weak AI benefits (which may increase at scale)
producing a solution is cheap / verifying the solution is cheap

This applies to tasks where AI tools might help people complete tasks more efficiently, but where the resulting impact or time savings are not significant. Over time/mass use, the benefits might increase.

Examples here include tasks like letter-writing and making summaries of documents or transcripts. If AI can do the initial grunt work, a human can take over and make tweaks to the output, nominally saving some time.

In our own field of civic tech, we can see this kind of tool being used to help people navigate bureaucracy: it might help format letters to representatives, or make effective appeals when FOI requests are refused.

Cheap processes at scale can also unlock new collective benefits. For instance, Muckrock uses LLMs to extract information and success/fail status from individual FOI responses. Doing this manually per request is easy for people, but requires lots of people to do the work to create a useful dataset across the entire corpus. An AI approach drops the costs further, which produces a small benefit on an individual scale, but collectively creates useful data.

As we note in our AI Framework, we have to recognise that a large number of small uses can build up into a negative effect. For instance, AI-created objections to planning applications might overwhelm a system that was built for a world in which there are higher hurdles to lodging an objection.

2. Significant AI benefits
producing a solution is expensive / verifying the solution is cheap

In this scenario, we’re thinking of situations where it is harder for a human to create a credible solution than it is to check if the outputs are valid. Conceiving a solution might be hard because it requires specialised knowledge, such as coding, or significant time and resources, like the analysis of a huge dataset; but it would be easy for a human to see whether or not the solution is working as intended.

One of the biggest practical uses of AI so far has been seen in coding, because coding problems fit so well into this category, and so provide potential benefits. The structure of computer code is often formally checkable (for at least syntax errors), and often there is a relatively short turnaround between “having code” and “checking the code is effective”. This isn’t to say that all coding fits in this box, but enough that a clearly productive set of tools exists.

There are strong potential benefits here because an expensive process can be made cheaper, while the quality of the output can be checked through relatively cheap verification methods.

This segment of applications can be impactful even where access to models is relatively expensive, as a relatively small number of LLM users can have a big impact through the products that emerge.

3. Get a human to do it
producing a solution is cheap / verifying the solution is expensive

Some LLM processes produce outputs that cannot be quickly verified by automatic or human means.

Here, using an LLM for the initial solution might be less effective than having a human do it from the start.  While tweaking an email that contains slightly poor wording is a cheap correction, adjusting a multi-page report written by an LLM (involving fact checking, correction, restructure, etc) might be more complicated than just having someone write the original work.

When humans approach a piece of work like this, the production and verification processes pretty much happen at the same time, because the skills required to produce the work are the same ones that suggest the work is valid.

“Use a human” is often most clearly the sensible approach for projects that need a high level of accuracy and confidence in the material produced. For example, we talked to OpenFun about their LawTrace site, which brings together legislative information in Taiwan. They made a point of choosing not to use AI at all in this project. Having accurate information was far more important to users than any convenience AI could introduce.

4. Break down the verification problem
producing a solution is expensive / verifying the solution is expensive

Sometimes solutions are expensive for a combination of reasons, and this can justify investment in trying to split the verification problem into smaller problems.

Through a sequence of different checks on LLM output, we can move problems towards being strong uses of AI, because it dramatically reduces the time needed to produce the solution, while the verification costs are manageable.

As an example, our APPG scraper sits in this category. We wanted to get accurate lists of parliamentary group memberships from dozens of different websites. Our original idea was that we would need to use a crowdsourcing approach, because we thought an LLM would be vulnerable to inventing lists of MPs.

But after some consideration, we invested time in a step where we could verify with code whether or the names extracted were actually listed on the relevant sites. We can see a similar example in the public consensus platform Pol.is – where category descriptions are linked back to concrete sources to facilitate easier double checking.

Similarly, you might find that aspects of your problem (if not the whole problem) are appropriate for mechanical checking. Could LLM code make a custom verification process easier? Can a series of automatic/human checks be made more efficient with a clear verification workflow? Each individual improvement moves your project closer to being a potentially strong use of AI.

Investment in the verification process might move the problem closer to having weak/strong AI benefits, where outputs can be derisked through cheap quality checks — but you’ll only know through systematically breaking it down in this way.

We hope that, by sharing this matrix, we will encourage more thoughtful deployments of AI technology in governments  and beyond. Please feel free to share it with those who will find it useful.

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This blog post has been adapted from our report Shifting Landscapes – A practical guide to pro-democratic tech.

Image: Leo Lau & Digit (CC-BY 4.0)

Key points

• Lowering the cost limit time would reduce the scope of the Freedom of Information Act, giving government departments greater leeway to deny requests.
• This  will have a disproportionate effect on high-impact Freedom of Information requests made by journalists and researchers. 
• It represents a new restriction on public scrutiny of government, counter to promises around improved government transparency, such as the promised roll-out of FOI to contractors providing government services. 
• It is unlikely to significantly reduce the volume of work required to process requests – local governments also receive a comparable volume of requests at a lower cost limit, and there are administrative costs even if a request is rejected under a new, lower cost limit. 
• Transparency is not a nice extra to have that can be cut when the budgets are tight. Governments that think they cannot afford transparency will be surprised at the corruption and inefficiency they will need to afford in its absence.
• The actual solution to volume is improved government processes. Reducing the cost limit might increase admin burden on authorities (due to increased back and forth with requesters) whereas better proactive publication genuinely could reduce volume of requests by removing the need to request in the first place.

What’s being proposed?

A policy is being floated, around decreasing the FOI cost limit in order to address an increase in the volume of requests. 

Financial Times: UK considers FOI clampdown as requests soar:

British officials are considering a clampdown on the freedom of information system in a move that would spark backlash from transparency campaigners.

Government figures are discussing a reduction in the cost ceiling for processing a request as the number of annual submissions has spiralled, according to people familiar with the situation.

The soaring number of requests comes against a backdrop of heavily constrained Whitehall budgets, they added.

There are no further details beyond this briefing. Our assumption is that the proposal is for a reduction to the central government cost limit (see below), but with no details on the scale implied. 

As reflected in the FT story, because of central government statistics, we can see that this increase mostly relates to defence records being moved to the National Archives. It is also worth putting in the context of a separate attempt to justify restrictions based on national security. 

What is the cost limit?

The “appropriate limit” is the time allowed to deal with an FOI request. 

At the start of the FOI process, a cost is estimated for the likely time it will take to locate, retrieve and provide the requested information (but not time taken in doing public benefits tests or applying redactions). 

It has a value in cash, but this is pegged against a set cost per hour (£25 an hour in UK FOI, £15 in Scottish FOI).  So effectively this is a time allowed in hours:

• £600 (40 hours) – Scottish FOI
• £850 (34 hours) – Parliamentary questions
• £600 (24 hours) – Central government FOI
• £450 (18 hours) – Other public bodies FOI

A related part of the rules is that authorities can aggregate similar requests (for similar information by connected people and made within 60 working days) and apply the cost limit to them collectively. Authorities may interpret this quite broadly if the requests share an overarching theme or are handled by the same team. 

Another relevant system is parliamentary questions, where the search time is pegged to 140% the cost limit for central government. The resulting ceiling is £850 (34 hours). 

How are the cost limits changed?

The cost limits for UK FOI are set by The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004. 

A new set of regulations could be made without a vote in Parliament.  The cost limits are changed via a statutory instrument passed by the negative procedure. This means the government lays the change before Parliament, and it automatically becomes law without a vote. 

MPs can sign a petition to call for a vote to annul it, but there is no automatic threshold where a certain number of signatures requires a vote. Generally it requires support of the official opposition to get a debate. 

What would be the effect of reducing the cost limit?

The likely effect of reducing the cost limit would be to prevent a class of currently useful and productive FOI requests, without significantly reducing volume or administrative costs. 

Who would this affect the most?

As the existing cost limit already rules out very broad requests, the change in any reduction would fall mostly on the most complex requests allowed by the current rules – and as such is likely to disproportionately affect journalistic and researcher use of FOI. Exploratory requests would need to be framed more narrowly, and a lower limit combined with the aggregation rule would make it easier for authorities to chain related requests together and deny them.

Any reduction in the central government cost limit would also have a knock-on effect on parliamentary questions, as the search time is linked. 

Would it reduce administrative costs?

This change would have a mixed effect on administrative costs: marking a bigger set of FOI requests as invalid has costs of its own. 

Reducing the cost limit would give more leeway to authorities to refuse requests when the documents requested are difficult to provide, but would be targeting a narrow band between what was previously acceptable and the new limit.  A lower threshold invites more dispute about the threshold, and requires justification for it falling in a narrow range, potentially causing more back and forth with requesters. What should happen in these cases is that authorities give advice and assistance on reducing the scope of the request to help fit inside the cost limit. Failing to do this has been noted in ICO decision notices about whether the exemption was applied correctly. As such, administrative savings are likely to be disappointing, as a lower cost limit creates work of its own. 

The natural experiment of the two different cost limits also does not suggest reducing would have a large effect on volume. The lack of comprehensive FOI stats means we do not have an up-to-date figure, but in 2017, local and central governments had comparable volumes of average FOI requests – despite the difference in the cost limit. 

What is a better approach to FOI volume?

Increased FOI volume raises the importance of efficient discovery and publication of information. Rather than reducing public transparency, public authorities should invest in their own processes and data to better meet internal and external needs. 

Public authorities need to be good at managing information — not just to answer FOI requests, but in order to work effectively. The effect of improved technology should be to make it easier for authorities to understand the information they hold, both for their own purposes and for public transparency.

More value can be realised by each FOI request released through improved disclosure logs. WhatDoTheyKnow.com removes the need for future FOI requests by making previous requests easier to find, with far more users of the site viewing information that has been published in previous FOI responses rather than making new requests. Public authorities can help reduce duplicate requests by publishing disclosure logs that make information released available to search engines (including AI agents), delivering more impact to releases and reducing repeated costs. This also helps address the social cost of atomised AI approaches: information is released for public benefit. 

Building on this, authorities can also learn from the subjects about  which  FOI requests are frequently made, and use that to inform their proactive publication of information. Increased volume of requests represents people making use of their information rights: this should be encouraged, while trying to make the process of finding and publishing information as efficient as possible. 

Transparency isn’t a cost: it’s a necessary investment for the rewards of reduced risk of corruption, and improved quality of work through the deterrent effect of future transparency. Efforts to cut costs could instead focus on the cost of secrecy— the high legal fees government departments have paid to try and keep secret information in the public interest. Government and parliamentarians should be invested in making this system work well, for the public benefit, rather than restricting access. 

Read other responses

• George Greenwood on Relight My FOIA blog on the security arguments being made
• Jenna Corderoy from Democracy for Sale on the money the government spends fighting transparency cases
• Claire Miller discusses cost limits in her weekly FOI news roundup
• Sunday Times – Our secrecy-addicted state is at it again. It must be stopped
• The Times – Curbing our right to know would be a blow to democracy

Header image: Photo by Jr Korpa on Unsplash

Our latest TICTeC work to help improve the impacts of civic technology takes its form in a collaboration with Sitra (the Finnish Innovation Fund). Together, we are exploring the development of a proposed European Civic Tech Hub.

As part of the Democracy Shield, the European Commission has committed to creating a European Civic Tech Hub as part of boosting societal resilience, citizens’ engagement and European digital sovereignty. 

Sitra is currently investigating what this hub could look like in practice, with the aim of addressing key barriers to civic tech adoption across the EU. As part of this work, we are helping them to engage with the civic tech and democratic innovation community, gathering insights, testing ideas, and identifying what would be most valuable for practitioners.

We hope by doing this, the perspectives of civic tech and democracy practitioners will be taken into account by the European Commission when planning the Civic Tech Hub and future civic tech initiatives.  And ultimately, that citizens can engage more effectively in democracy across Europe. 

Our aim is to publish findings in a public-facing report in June 2026.

Get involved

As part of this research, we’re conducting interviews with civic tech practitioners (especially in the civic participation space) as well as deliberative democracy practitioners between mid-March and the end of April 2026. 

If you’re a civic tech or deliberative democracy practitioner and would like to share your perspective on the proposed EU Civic Tech Hub, then please get in touch by filling out this form, or emailing tictec@mysociety.org.