Is public consultation enough? What Wales found

A Welsh Government advisory group published its progress report on democratic renewal in Wales this month. Buried in the detail is a pointed observation about public consultation: that it is “rarely sufficient and hugely overused.” We think that deserves a closer look.

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What did the Welsh Government’s advisory group actually say?

The Innovating Democracy Advisory Group (IDAG), established by the Deputy First Minister to advise on democratic reform in Wales, published its progress report in March 2026. It is a serious document, worth reading by anyone working in public participation across the UK.

Most of the report concerns democratic education, public involvement between elections, and the case for a long-term national strategy for Welsh democracy. But one passage stopped us. In describing what meaningful public involvement should look like, the report says this: involvement must go beyond informing people and engaging in consultation; whilst these have a place, they are rarely sufficient and hugely overused.

That is a striking statement from a body advising a devolved government. The implication is that consultation, as routinely practised, falls well short of what genuine democratic engagement requires. We agree with parts of that analysis. But the framing also invites a more precise examination of what the problem actually is.

Is consultation really overused, or is it just used badly?

The IDAG report draws a distinction between informing people, consulting them, and involving them meaningfully in decision-making. It draws on a spectrum familiar to participation specialists, in which consultation sits some way below co-production, collaboration and deliberation in terms of the depth of public influence over decisions.

That spectrum is real and useful. But the argument that consultation is overused conflates two quite different problems.

The first is volume. Some organisations do run too many consultations, on questions where the decision has already been made, or where the subject matter does not genuinely warrant public input at all. We see this. It wastes everyone’s time and trains respondents to be cynical.

The second is quality. Far more common, in our experience, is not too much consultation but consultation done poorly. A survey designed to confirm a preferred outcome rather than genuinely test it. A consultation period too short for substantive responses. A decision already taken before the process opened. These are failures of process, not failures of frequency.

The Gunning principles, the legal test for fair public consultation in the UK derived from R v London Borough of Brent ex parte Gunning [1985] and confirmed by the Supreme Court in R (Moseley) v London Borough of Haringey [2014] UKSC 56, set out what lawful consultation requires. Consultation must happen when proposals are still formative, with enough information for an intelligent response, over adequate time, and with conscientious consideration of what is received. An organisation that follows those four requirements is not running a tick-box exercise. It is doing something genuinely valuable.

The IDAG report acknowledges that consultation has a place. What it argues, correctly, is that consultation alone cannot deliver the kind of democratic partnership it is seeking. On that, we have no quarrel.

What does the Welsh context tell us about participation more broadly?

Wales is an interesting case precisely because it has gone further than most in embedding public involvement in law. The Wellbeing of Future Generations (Wales) Act 2015 places a statutory duty on public bodies to involve people in decisions affecting their lives. The Social Services and Well-being (Wales) Act 2014 embeds co-production as a core principle. Local authorities are required to have public participation strategies. The legislative architecture for meaningful involvement is already there.

And yet the IDAG report found that involvement has not been consistently mainstreamed. Its summary of findings is frank about the gap between statutory expectation and day-to-day practice: cautious risk cultures, limited capacity, lack of political leadership, and the practical difficulty of embedding different ways of working into existing processes. In other words, Wales has the framework. What it lacks is the culture and the capability to make that framework live.

This is a finding that applies well beyond Wales. The Carnegie UK Life in the UK: Wales 2025 report, cited by IDAG, found low trust in devolved government and a widespread sense among people in Wales that they have little influence over decisions that affect them. That is not a problem consultation alone caused. But it is a problem that poorly designed consultation, run as a procedural requirement rather than a genuine exercise in listening, has certainly not solved.

What should organisations take from this?

The IDAG report’s call to move beyond consultation is not, on careful reading, an argument against consultation. It is an argument for taking public involvement seriously as a whole, of which lawful and well-designed consultation is one part.

There are three things we think practitioners and commissioners should draw from this.

The first is that consultation quality matters more than consultation volume. An organisation that runs fewer consultations but runs them properly, with clear questions, genuine openness to outcomes, and a documented account of how responses influenced the final decision, is serving its stakeholders better than one that consults constantly but superficially.

The second is that consultation and deeper involvement methods are not in competition. Citizens’ assemblies, deliberative panels, community co-design processes and formal consultations serve different purposes at different points in a decision-making process. The IDAG report’s evidence review on mainstreaming participatory and deliberative democracy in Wales, commissioned from the Democratic Society, sets out the international evidence on how these methods can be combined. That combination works best when the purpose of each is clearly defined.

The third is that the IDAG report identifies a governance failure, not just a method failure. Its sharpest observation is not that consultation is bad but that responsibility for democratic engagement is fragmented, under-resourced and not taken seriously at senior levels. That is precisely the kind of consultation risk that tCI has been documenting for years. When democratic participation is no one’s explicit responsibility, it defaults to the path of least resistance. Usually, a survey.

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How tCI Can Help

Organisation Wide Learning Hub Access
Equip your entire team with professional consultation skills through one platform. Self paced courses, live virtual classrooms, practical toolkits and expert resources that build a shared baseline of competence across your organisation. Trusted by councils, NHS bodies and regulators nationwide.

Bespoke Training Workshops
Training that works with your real projects, not hypothetical scenarios. Sector tailored sessions help teams apply good practice to live challenges: sharpening consultation documents, building defensible codebooks, strengthening equality analyses. Half day or full day workshops for health, local government, planning and public service teams.

Coaching for Complex or High Risk Consultations
Expert guidance when the stakes are highest. One to one and small group coaching for senior officers navigating legally exposed or politically contentious decisions. Strengthen your judgement on proportionality, evidence standards and challenge management. Essential for organisations that may face judicial review risk or major service changes.

Whether you’re preparing for a high stakes service change, building long term consultation capability, or need confidence that your evidence approach will stand up to scrutiny, we can help.

Contact tCI: hello@consultationinstitute.org