What we learned making a standards complaint
Through Parliamentary written questions, MPs and Peers can ask for information and documents from government departments. But as part of that, they’re supposed to declare if they have any relevant financial interests that relate to the question they’re asking. This provides ( incomplete ) transparency on where the access they’re given in the public interest is also mixed with potential private benefits.
We’ve recently raised a successful complaint about a set of questions tabled by Nick Timothy MP, who has apologised for the missing declaration . This blog post covers what we learned from making that complaint, and the potential for expanding the scope of our work on highlighting missing interests.
Exploring written questions
As part of research investigating parliamentary written questions, we discovered that a set of similar questions had been asked without an interest being declared, but where we thought there were relevant interests that should have been declared.
We want to explore how we can use our data to improve compliance with Parliament’s existing rules. One of our concerns is that Parliament periodically adopts stronger transparency rules, but in practice there is a lack of proactive enforcement . As we are in favour of stronger rules, understanding how to encourage better enforcement of existing rules is important for our goal of raising standards.
There is an existing avenue to address this. The Parliamentary Commissioner for Standards takes complaints from members of the public, and will then decide whether to open an investigation.
This is not something we’d done before at mySociety, and we reviewed previous complaints to have some idea of the expected form and outcomes. We’ve learned more about the threshold for a complaint to be accepted, and this is already informing how we approach our future work.
Our complaints
We raised two complaints about MPs from different parties. One was rejected as we had not “adequately explained” the breach of the rules. The other, about Nick Timothy, was accepted.
In our report about we raised issues with three sets of his parliamentary questions:
- A declaration about an oral question;
- Two questions we thought should have been associated to a donation he received from the racehorse auctioneers Tattersalls;
- Four questions we thought should be associated with a gift of honorary membership he received from the Jockey Club.
The Commissioner only accepted the last of these three:
“I will only be investigating Mr Timothy’s alleged failure to declare an interest when tabling his four written Questions of December 2025. I will not be investigating your allegation about his oral Question of 6 February 2025. This is because, by virtue of paragraph 7(a) of Chapter 2 of the Guide to the Rules, oral Questions do not need to be accompanied by a declaration. I also will not be investigating your allegation that a declaration was needed in respect of Mr Timothy’s written Questions of 10 June 2025. This is because I am not satisfied on the evidence available that the test of relevance was met.”
The first issue we raised was around Parliament’s rule about clear declarations of interests: Timothy had referenced his register of interest in an oral question, but not specified which interest he was referring to (which is the requirement of the current rules for debates). In this case, knowing which interest he meant would have been useful in judging if he was aware of the relevance of the same interest at other times.
The rule the Commissioner referenced in response was that an interest does not need to be declared “[i]f to do so would unduly impede the business of the House; for example, during oral Questions, when asking supplementary Questions, or when responding to a Ministerial statement.” This reflects the general problem that declarations on questions are held to a lower standard in the rules than speeches (and oral questions to a lower standard than written questions) — but fair enough, that’s the rule.
The second set is interesting and tells us how directly connected an interest and a question needed to be. In this we connected a pair of questions about horseracing and then pending gambling reform to a donation from Tattersalls referenced in the register.
Tattersalls is not in itself a gambling company. Our view is that there is a cluster of related industries that make up the horseracing industry, all of whom depend directly or indirectly on the connection between horseracing and gambling. Indeed, in our complaint, we quoted the chairman of Tattersalls from their annual report, explicitly highlighting how gambling regulation affects them as part of the wider industry.
However, this was judged not to pass the test of relevance, which from the Code of Conduct is “whether those interests might reasonably be thought by others to influence his or her actions or words as a Member” .
From our perspective, looking at the questions and interests in aggregate, we see a set of donations from the horseracing industry, and in parallel a set of questions that relate to the big push by that industry around gambling reform at the time. This is not to say one happens because of the other, but that they’re a relevant fact to highlight. However, to engage the investigation, we need to draw a connection between a specific interest and a specific question. In this case, the commissioner judged there were too many hops.
For the third set, we had a more direct argument. This highlighted a set of questions that relate to racehorse training yards or racecourses,and highlighted that the Jockey Club (of which Timothy has an honorary membership) describes itself in its SIC code and accounts as operating sports facilities and training facilities for racehorses.
This was judged to be relevant, and at the conclusion of the investigation, Timothy has apologised and said there should have been an interest declared :
On a point of order, Madam Deputy Speaker. I am an honorary member of the Jockey Club Rooms, which provides accommodation and function rooms in Newmarket. It is an offshoot of the Jockey Club, and I accepted the membership to support a valued local institution. I declared this in the Register of Members’ Financial Interests, but did not repeat the declaration when I tabled four written parliamentary questions regarding the taxation of training yards and racecourses. The Parliamentary Commissioner for Standards accepted that I tabled the questions because of their relevance to the local economy, and understands that my error was inadvertent. None the less, I accept his advice that I should have declared this interest a second time when I tabled the questions, and I apologise to the House.
We’re happy with this outcome, because we do not think the rules for declarations for written questions are unreasonable, or an especially high bar to meet. If MPs want to accept gifts to support local industries, then yes, they do then need to pay more attention when asking questions that are relevant to those local industries. We hope this apology raises awareness of the rules and encourages others to get the basics right.
More details of the communications between the Commissioner and Nick Timothy can be read in the evidence pack the Commissioner published.
What have we learned from this?
Our goal here was not specifically about Nick Timothy, but that this undeclared interest is part of a pattern we had found around undeclared interests in written questions, and we wanted to understand more about making complaints to engage the parliamentary standards process.
Our key takeaway is that we get a different perspective on the threshold for an investigation from our failed approaches than we did from our initial work reviewing existing cases.
From reading the Commissioner’s previous decisions it seemed like there was a low bar for the reliance test. However, these are the decisions that were adopted, and may have passed some other criteria to reach that point. Often, the MP themselves have self-referred after receiving an accusation — which may signify from the start that there is something to investigate.
The key point we took from this is that a member of the public making a complaint needs to draw a clear and direct connection between a specific interest and a specific question. While more indirect arguments can be made (and we’d argue, can be valid), it is at the discretion of the commissioner whether these are adopted.
Expanding the net
We’ve extended our approach to review 82k written questions asked since June 2025. Based on this we have candidates for future investigation and complaints.
But the initial data matching is the easy part. To go through the complaints system, we need to put research into developing the sharpest examples. Our experience with these first attempts gives us a sense of both the level of detail required, but also where complaints (which might reasonably still highlight violations of the rules) are unlikely to succeed. This helps us prioritise and shape our approach, as well as exploring alternate approaches where we can make better use of our information.
AI and complaints processes
This also interacts with our thinking about AI and demand on public services , and especially complaints mechanisms .
We did not use AI to write complaints (which has clear risks in hallucinating specific rules or connections) but did use AI technologies in the data matching — which has dramatically lowered the costs and time of a complicated fuzzy match between the questions and interests datasets.
Our view is that this makes it easier for us to make legitimate complaints. An exercise of systematically detecting (and complaining about) questions without relevant declarations is much more viable than it would have been a few years ago.
But resourcing at the other end has not changed, and engaging the standards system requires going through the Commissioner. Alongside that, the Commissioner (alongside other complaints mechanisms) might be seeing an increase in complaint volume from more direct use of AI complaints.
An increase in volume of reports from us (or AI-driven reports in general) might result in the kind of rationing of time where only the most direct examples proceed — which is not what we want: many of the examples that concern us most require a lens that operates with a slightly broader view than that.
As such, we need to think about when complaints are the right mechanism, versus where we want to be building broader cases about the intersection of public roles and private interests.
How you can help
Our goal is to raise standards in our political system. What we need most at the moment is time to understand the data we now hold and to develop new pipelines for having an impact with it.
Your donations help give us that time to dig, research, and build new approaches – that make a real difference to how politics works.
Read more about the work we’re doing.
Header image: Photo by Lorenzo Spoleti on Unsplash