Policing: Merger of police services into one force per devolved nation and English region

Ministerial submission

To: The Home Secretary

Issue

1. England and Wales are policed by 43 territorial forces — 39 in England and 4 in Wales — ranging in size from forces of under 1,000 officers to the Metropolitan Police Service with over 33,000. This structural fragmentation produces inconsistency in standards, duplicates back-office functions, and constrains the specialist capability required to respond to serious, organised, and cross-boundary crime. Your White Paper of January 2026 proposes addressing this through a three-tier model — a new National Police Service, approximately 12 regional super-forces, and local policing areas within each super-force — with an independent structural review commissioned to report by Summer 2026. This submission examines whether the proposed consolidation goes far enough.

Background

2. The current structure of 43 forces in England and Wales dates substantially from the Local Government Act 1972 and the Police Act 1964, which reduced a post-war landscape of over 120 forces through a series of mergers. A further round of mergers was proposed in 2006 by Home Secretary Charles Clarke, who sought to reduce the 43 forces to approximately 24 strategic forces; the proposals were abandoned within months following opposition from chief constables, police authorities, and local government, and the significant upfront costs estimated at over £600 million. Police and Crime Commissioners, introduced by the Police Reform and Social Responsibility Act 2011, subsequently entrenched local accountability as a structural feature, giving each force area a directly elected commissioner holding the chief constable to account.

3. Scotland’s experience is instructive. Police Scotland was established on 1 April 2013, merging eight regional forces and the Scottish Crime and Drug Enforcement Agency. The merger was achieved but at considerable cost: the integration was rushed into 18 months; legacy IT systems from all eight forces took over a decade to harmonise; cultural resistance was significant; and call-handling failures attracted sustained public and media criticism. Audit Scotland described the financial case as unclear. The Scottish merger has been described by academic observers as a cautionary tale for any replication South of the border, though Police Scotland has stabilised and its roughly 16,000 officers now operate as a functioning national service. The PSNI, by contrast, has operated as a single force since 2001, though its current strength of around 6,000 officers falls well below the Patten Report’s target of 7,500.

4. The January 2026 White Paper represents the most significant structural reform proposal since the 2006 Clarke proposals. Its three-tier architecture — national, regional, local — is intended to consolidate specialist and serious crime functions nationally, achieve economies of scale at regional level, and preserve neighbourhood visibility through a sub-force local tier. The Institute for Government has assessed the case for a National Police Service as strong but the case for regional super-force mergers as “much weaker”, noting the risk of power shifting substantially to large regional forces and the Home Office at the expense of local accountability.

5. You have committed to proceeding with the White Paper’s structural review and to implementing the three-tier model. In Wales, the question of devolution of policing has acquired sharper political salience since the Senedd’s February 2026 vote of 38 to 14 in favour: the absence of a substantive Government response was cited by the outgoing First Minister, following the change of administration in Wales in May 2026, as evidence of inadequate engagement with the devolution settlement. This submission responds to your commitment to improved national and regional policing by examining whether the regional consolidation element of the White Paper should be more radical in its ambition.

The General Case

6. The case for more radical consolidation beyond the White Paper rests on four grounds:

• (a) economies of scale in procurement, training, IT, and specialist functions are greatest at the largest viable unit of organisation; stopping at 12 forces leaves significant duplication that a smaller number would eliminate;
• (b) HMICFRS inspections have consistently found that smaller forces struggle to maintain the full range of specialist capability — serious crime investigation, public protection, firearms, cyber — that larger forces can sustain; fewer, larger forces address this structurally rather than through ad hoc collaboration arrangements;
• (c) public confidence in policing has fallen from 79% in 2015-16 to 67% in 2024-25; the case that performance improvement requires structural reform is increasingly accepted;
• (d) the White Paper itself acknowledges that the current structure is inadequate; going further requires only accepting the same logic more fully.

7. The case against further consolidation beyond the White Paper also rests on substantial grounds:

• (a) Police Scotland’s formation demonstrates that the management challenge of merger is substantial and that rushing it produces lasting damage; further consolidation beyond 12 forces multiplies this risk;
• (b) community policing depends on local knowledge and public trust, both of which are harder to maintain in larger, more remote organisations;
• (c) PCCs provide direct democratic accountability to local populations; replacement mechanisms in merged forces — whether regional commissioners or police boards — are likely to be less directly accountable;
• (d) a single English force at approximately 140,000 officers would be by far the largest police organisation in any democratic country, roughly eight times the size of Police Scotland, for which there is no precedent or evidence of manageability.

Options

Option A: Proceed with the White Paper’s three-tier model

8. Under this option, the White Paper’s proposed consolidation to approximately 12 regional super-forces in England and Wales, alongside a new National Police Service absorbing serious and organised crime functions, is implemented following the independent structural review.

9. For:

• (a) represents settled government policy, already the subject of an independent review, and avoids re-opening a structural debate that has generated significant institutional resistance in the past;
• (b) the three-tier model preserves a local policing layer, providing some mitigation against the accountability and community policing concerns raised by larger units;
• (c) the National Police Service addresses the most acute cross-boundary capability gaps without requiring wholesale regional merger.

10. Against:

• (a) 12 forces in England and Wales still represents substantial structural complexity; the economies of scale, IT standardisation, and specialist capability benefits are greater with fewer forces;
• (b) the local policing tier within each super-force creates a three-layer management structure of uncertain effectiveness;
• (c) the 2006 experience suggests that partial merger proposals can lose coherence and be abandoned mid-implementation; a more decisive consolidation may be more resilient politically;
• (d) 12 forces for England and Wales — presumably one for Wales and eleven for England — does not align with the nine traditional English regions that the ONS and government offices have used for decades as the standard sub-national geography, creating a new set of force boundaries whose rationale and long-term durability is unclear.

Option B: One force per English region and one Welsh force

11. Under this option, the 39 English forces would be consolidated into nine regional forces corresponding to the established English regions, and the four Welsh forces merged into a single Welsh service. The National Police Service would be retained as proposed in the White Paper. PCCs would be replaced by directly elected regional police commissioners with mandates covering each new force area. Total forces in England and Wales: ten, plus the National Police Service.

12. For:

• (a) ten forces of approximately 14,000-16,000 officers each is closely comparable to Police Scotland’s scale, making its operational experience — both its difficulties and its subsequent stabilisation — directly applicable as a design template;
• (b) nine English forces and one Welsh force aligns precisely with the nine traditional ONS regions of England, providing boundaries with established administrative, statistical, and public recognition rather than requiring a new regional geography to be invented and legitimised;
• (c) consolidating Wales to a single force aligns with the strong cross-party consensus in the Senedd for devolution of policing to Wales, creating the institutional basis for that devolution to follow;
• (d) regional force boundaries would align with emerging combined authority and mayoral structures, providing a coherent basis for the accountability mechanism.

13. Against:

• (a) consolidating nine forces into one in each English region requires merging between two and seven existing forces per region, replicating at scale the cultural integration, IT harmonisation, and financial challenges that characterised Police Scotland’s formation;
• (b) regional elected commissioners, covering populations of three to ten million, would have weaker relationships with local communities than current PCCs, whose mandate covers a single force area;
• (c) alignment with English regional boundaries imports their contested legitimacy: the regions have no democratic institutions and are not uniformly recognised as meaningful units of governance.

Option C: Single English force and single Welsh force

14. Under this option, all 39 English territorial forces would be merged into a single England Police, and the four Welsh forces into a single Wales Police, replicating the model of Police Scotland and the PSNI at the level of each nation. National functions would be absorbed into the National Police Service. Total forces in England and Wales: two, plus the National Police Service.

15. For:

• (a) provides the maximum economies of scale and the fullest elimination of cross-boundary coordination failures within each nation;
• (b) creates a directly analogous structure across all four nations of the United Kingdom, providing a coherent constitutional settlement for policing at national level;
• (c) a single Wales Police would provide the clearest institutional basis for the subsequent devolution of policing to the Senedd canvassed in the Background.

16. Against:

• (a) a single English force at approximately 140,000 officers would be an organisation of unprecedented scale among democratic policing services, larger than the national police forces of France, Germany, or Italy; the management challenge has no direct precedent;
• (b) the Metropolitan Police Service, with its unique capital and national security functions, would require special consideration or a specific carve-out, substantially complicating the merger;
• (c) the political and institutional resistance to abolishing 39 named English forces — many with deep local identities — would be substantially greater than for the White Paper’s regional model, and comparable to the factors that defeated the 2006 proposals.

Resource and Cost Implications

17. The White Paper’s three-tier model carries its own estimated implementation costs. Options B and C would require comparable primary legislation and more extensive transitional arrangements. The 2006 proposals estimated upfront merger costs of over £600 million for a less radical consolidation; Options B and C would exceed this significantly, though the long-term savings from reduced duplication, shared IT, and rationalised back-office functions are likely to be proportionally greater. Detailed cost modelling would be required before either option could be committed to.

Legal and Devolution Considerations

18. The legislative framework for policing in England and Wales — principally the Police Act 1996 and the Police Reform and Social Responsibility Act 2011 — would require replacement or substantial amendment under any further merger. Policing is not currently devolved to Wales; Options B and C both create a logical precondition for devolution by establishing a single Welsh force, but the question of whether devolution should precede or follow merger would need to be determined. The Northern Ireland position is unaffected by any of these options; PSNI operates under separate legislation and the Patten accountability framework.

19. Under all options, the Police and Crime Commissioner model would need to be replaced. The current 41 PCC positions in England and Wales provide a form of direct democratic accountability that any merger must replace with an equivalent or superior mechanism; the design of that mechanism — whether elected regional commissioners, police boards, or an enhanced HMICFRS scrutiny function — is a substantive democratic question that should be resolved before force boundaries are fixed, not after.

Requested direction

20. Ministers are invited to determine whether the consolidation proposed in the White Paper goes sufficiently far; and, if not, to indicate whether a regional model of ten forces (Option B) or a national model of two forces (Option C) should be considered by the independent structural review alongside the White Paper proposals.