This post documents my judicial review application challenging the House of Lords Commissioner for Standards’ refusal to require Lord Hermer to declare his Matrix Chambers directorship upon entering the Lords.
Claim for Judicial Review Wright v Commissioner for Standards, House of Lords, 3 July 2025 (Form N461).
Details of the decision to be judicially reviewed [if accepted for review]
Decision 1 (6 May 2025): Commissioner dismissed my complaint as "vexatious" for referencing Companies Act/Companies House, misapplying paragraph 11 of the Enforcement Procedure.
Decision 2 (16 May 2025): Commissioner dismissed revised complaint, wrongly stating Lord Hermer had "no requirement" to register Matrix Chambers, misinterpreting Paragraph 40 (Guide, 13th Ed.).
Decision 3 (22 May 2025): Commissioner (via Standards Clerk) confirmed the decision is final, and wrongly asserted that initial registration need not reflect interests at introduction.
Decision 4 (23 May [at 13:02 and 14:26] & 13 June 2025): Registrar thrice refused to clarify registration requirements or refer the issue to the Conduct Committee, despite duty under Guide p.7.
Date of decision: 6/5/2025
Name and address of the court, tribunal, person or body who made the decision to be reviewed: Commissioner for Standards, House of Lords.
Does any part of the claim allege a breach of Convention rights protected under the Human Rights Act? Yes.
Identify the Convention rights you contend have been breached in the box below:
Breach of Article 6 ECHR: Commissioner’s dismissal ignored evidence and misapplied Code provisions (¶40/46), denying substantive review. Registrar’s refusal to clarify rules obstructed access to interpretive guidance. "Vexatious" designation without merit assessment violated procedural fairness.
Statement of facts relied on:
Vexatious Complaint Designation (6 May 2025):
The Commissioner dismissed my original complaint as “vexatious” due to references to the Companies Act 2006 and Companies House identities, despite the complaint’s primary focus on breaches of the House of Lords Code of Conduct (non-registration of directorships). I was instructed to revise and resubmit my complaint, excluding these references.
Dismissal of Revised Complaint (16 May 2025):
My revised complaint (7 May 2025), focused solely on Code of Conduct breaches, was dismissed on the basis that Lord Hermer had “no requirement” to register his Matrix Chambers directorship, as he resigned within one month of introduction. The Commissioner misapplied Paragraph 40 of the Guide (13th Ed.), treating the one-month deadline as a grace period rather than a requirement to declare all interests held at introduction. Paragraph 46, requiring late-registered interests to remain public for one year, was ignored.
Final Dismissal and Closure of Appeal (22 May 2025):
The Commissioner’s office (via the Standards Clerk) confirmed the decision was final and stated that the Guide does not require registration of interests held at the moment of introduction, closing off any right of appeal and reinforcing the earlier misinterpretation.
Registrar’s Refusal to Clarify (23 May [at 13:02 and 14:26] & 13 June 2025):
The Registrar thrice refused to clarify the requirements for initial registration or refer the matter to the Conduct Committee, despite the statutory duty to advise on registration rules (Guide, p. 7). The Registrar stated it was not their role to make public pronouncements on Code interpretation, contradicting published duties.
Detailed statement of grounds:
1. Illegality (Decision 1):
The Commissioner acted ultra vires by dismissing the complaint as “vexatious” without assessing its merits, contrary to Paragraph 11 of the Enforcement Procedure, which requires dismissal only if “unsupported by evidence.” This also breached procedural fairness by disregarding my good-faith revision.
2. Irrationality (Decision 2):
The Commissioner’s interpretation of Paragraph 40 (Guide, 13th Ed.)—that interests resigned within one month of introduction need not be registered—renders the Register meaningless for interests held at introduction but quickly resigned. This conflicts with Paragraph 3(b) of the Code, which requires “openness and accountability.”
3. Procedural Unfairness (Decisions 3 & 4):
The Commissioner’s final response (22 May 2025) closed off any right of appeal and reinforced a misinterpretation of the Code. The Registrar’s repeated refusals to clarify the registration requirements or refer the issue to the Conduct Committee breached the Guide’s duty to “advise members and consult the Committee when necessary” (Guide, p. 7). This denied access to interpretive guidance and undermined fair process (Article 6 ECHR).
4. Breach of Human Rights (Article 6 ECHR):
The cumulative effect of the Commissioner’s dismissals and the Registrar’s refusals was to deny me a fair hearing and a meaningful opportunity to have my complaint substantively considered, in breach of Article 6 ECHR.
Details of remedy (including any interim remedy) being sought (Section 8)
Quashing Orders:
Overturn both dismissal decisions (6 May and 16 May 2025).
Mandatory Orders:
1. Commissioner reinvestigates the complaint using correct interpretation of Paragraph 40.
2. Registrar issues public guidance on initial registration requirements.
Declarations:
1. Interests held at introduction must be registered even if resigned within one month.
2. Removal of Paragraph 46 in Revised Code (2025) weakens transparency and conflicts with Companies Act 2006
Damages under Section 8 of the Human Rights Act 1998:
Compensation for anxiety/distress caused by procedural unfairness (Article 6 breach
Supporting Documents – Section 10
[As submitted in Judicial Review Claim Form:]
1 Original complaint to the Commissioner for Standards (28 April 2025) pages 21-29.
2 Revised complaint (7 May 2025) pages 31-33.
3 Commissioner’s dismissal letters (6 May, 16 May, 22 May 2025).
• Letter (email correspondence) 6 May 2025 pages 35-43.
• Letter of 16 May 2025 page 44.
• Letter (email correspondence) 22 May 2026 pages 45-52.
4 Registrar’s correspondence (23 May, 13 June, 25 June 2025) pages 54-62.
5 Companies House records for Lord Hermer page 63.
6 Pre-2025 Guide to the Code of Conduct (extracts: Paragraphs 40, 46) page 64
The supporting documents submitted with the claim, were complete. The email correspondence included repetitions of previous correspondence, embedded within the email chain. Whilst this had the benefit of showing the email provenance, this created unnecessary duplication, which I do not want to recreate herein.
To aid understanding, the supporting documents are provided below in chronological order, with repetition of previous emails removed and naming convention standardised. The page references relate to the location in the original Judicial Review document and remain for the purpose of traceability.
Supporting Documents – Section 10 arranged chronologically on 7/7/25.
Commissioner for Standards’ correspondence:
Wright’s original complaint to the Commissioner for Standards (28 April 2025) (pages 21-29.)
Commissioner’s dismissal letter (6 May 2025) (pages 35-43).
Wright to Commissioner - revised complaint (7 May 2025) (pages 31-33).
Commissioner’s dismissal letter (16 May 2025) (page 44).
Wright to Commissioner (18 May 2025) (pages 45-52).
Commissioner’s dismissal letter (22 May 2026) (pages 45-52).
Registrar of Lords’ interests’ correspondence (pages 54-62):
Wright to Registrar (23 May 2025 at 10.26).
Registrar’s first response (23 May 2025 at 13.02).
Wright to Registrar (23 May 2025 at 13.19).
Registrar’s second response (23 May 2025 at 14.26).
Wright to Registrar (23 May 2025 at 18.34).
Wright to Registrar (12 June 2025).
Registrar’s third response (13 June 2025).
Wright to Registrar of Lords’ Interests (25 June 2025).
Companies House records for Lord Hermer (page 63).
Pre-2025 Guide to the Code of Conduct (extracts: Paragraphs 40, 46) (page 64)
1. Commissioner for Standards’ correspondence:
1a. Wright’s original complaint to the Commissioner for Standards (28 April 2025) (pages 21-29).
“To: The House of Lords Commissioner for Standards House of Lords London SW1A 0PW Email: lordsstandards@parliament.uk
Date: 28 April 2025
Subject: Formal Complaint Against Lord Hermer (HM Attorney General) for Breaches of the Code of Conduct and Statutory Inconsistencies
Dear Commissioner,
I am writing to formally complain about Lord Hermer’s failure to register directorships under the House of Lords Code of Conduct and to highlight a critical inconsistency between the Revised Code of Conduct (5 April 2025) and the Companies Act 2006.
Summary of Alleged Breaches
Failure to Declare Directorships:
Lord Hermer’s Register of Interests omits multiple directorships (Matrix Chambers Limited, The Harbour Foundation, and the Incorporated Council of Law Reporting for England and Wales) despite Companies House records confirming their existence12.
These omissions violate the pre-5 April 2024 Code of Conduct, which required registration of all directorships under Categories 1 (remunerated) or 10 (non-financial).
Statutory Inconsistency:
The Revised Code of Conduct (effective 5 April 2025) removes the requirement to declare non-financial interests. This conflicts with the Companies Act 2006, which imposes duties on directors (including Lords serving as company directors) to declare all interests that could create conflicts345.
Legal Inconsistency Between the Revised Code and Companies Act 2006
The Revised Code’s deletion of Category 10 (non-financial interests) creates a regulatory gap that undermines compliance with the Companies Act 2006:
Section 175: Directors must avoid conflicts of interest, including those arising from non-financial roles (e.g., unremunerated directorships)67.
Section 177: Directors must declare any interest in a proposed/actual transaction, regardless of financial gain8.
By exempting non-financial interests from registration, the Revised Code:
Erodes transparency: Lords serving as company directors may omit roles that could influence parliamentary actions, breaching statutory duties under the Companies Act.
Creates legal risk: A member’s failure to disclose a directorship (even unpaid) could lead to conflicts of interest unaddressed by the Code, exposing them to litigation under company law9.
Request for Investigation
Compliance with Pre-5 April 2024 Code: Investigate Lord Hermer’s failure to declare directorships held prior to 5 April 2025, which were registrable under the Code in force at the time.
Review of Statutory Compliance: Assess whether the Revised Code’s removal of non-financial interest declarations aligns with the Companies Act 2006, particularly given Parliament’s intent to ensure directors’ accountability for all conflicts10.
Supporting Evidence:
Companies House records for Richard Hermer/Richard Simon Hermer (directorships and resignation dates).
Extracts from the Register of Lords’ Interests (April 2025).
Hansard debates (2006) and legal analyses confirming the Companies Act’s broad conflict-of-interest scope357.
Yours sincerely,
Alison Wright
Attachment: Compliance Assessment
Compliance assessment of the UK Attorney General, Richard Hermer.
Contents:
Register of interest
Lord Hermer’s Companies House records
Comparison of interests registered in Companies House, with Lord Hermer’s Register of Interests.
Complaint about Lord Hermer to the Lords Commissioner for Standards
Total number of appointments 1 - Born September 1968
102 Petty France, London, England, SW1H 9AJ
Richard Simon HERMER
Total number of appointments 3 - Born September 1968
1 New Change, London, EC4M 9AF".
As Attorney General, Lord Hermer may have authority to establish two identities. He has used two versions of his name for each identity, one with a middle name, as Richard Simon Hermer. If the correct authorities have not been provided, then he has breached section 1082 of the Companies Act 2006.
The appointments held by these identities are:
Identity 1
"Richard HERMER
Total number of appointments 1 Date of birth September 1968
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034)
Company status Active Correspondence address 102 Petty France, London, England, SW1H 9AJ Role Active Director Appointed on 5 July 2024 Nationality British Country of residence England Occupation Lawyer".
Identity 2
"Richard Simon HERMER
Total number of appointments 3 Date of birth September 1968
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 7 October 2023 Resigned on 2 August 2024 Nationality British Country of residence United Kingdom Occupation Barrister
THE HARBOUR FOUNDATION (00975116) Company status Active Correspondence address 1 Red Place, London, W1K 6PL Role Resigned Director Appointed on 1 March 2017 Resigned on 7 July 2024 Nationality British Country of residence United Kingdom Occupation Barrister
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 3 March 2016 Resigned on 17 February 2021 Nationality British Country of residence United Kingdom Occupation Barrister".
Comparison of interests registered in Companies House, with Lord Hermer’s Register of Interests.
Lord Hermer failed to declare his directorships of:
Matrix Chambers Limited, (Appointed on 3 March 2016 Resigned on 17 February 2021 and Appointed on 7 October 2023 Resigned on 2 August 2024) and
The Harbour Foundation, (Appointed on 1 March 2017 Resigned on 7 July 2024).
Matrix Chambers and The Harbour Foundation are category 1 directorships which Lord Hermer has a duty to declare in his Register of Interests. This is prima facie evidence that Lord Hermer failed to declare these interests in breach of the Code of Conduct.
On 5th April the Revised Code of Conduct no longer required “Non-financial” interests to be declared. Hence the following active role is no longer visible in his current register of interests as it was deleted on 5th April 2025.
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034) Role Active Director Appointed on 5 July 2024.
The Revised Code of Conduct for the House of Lords (effective 5 April 2025), which removes the requirement to declare non-financial interests, raises significant concerns about consistency with the Companies Act 2006, particularly regarding directors’ duties to avoid conflicts of interest and declare relevant interests. Here’s a structured analysis:
Key Points of Contention
Revised Code of Conduct Changes
Non-financial interests (e.g., unremunerated directorships, trusteeships) no longer require registration4.
Category 10 (Non-financial interests) has been deleted entirely4.
Focus shifted to “relevant financial interests” as the primary registrable category14.
Companies Act 2006 Requirements
Section 175: Directors must avoid conflicts of interest, including those arising from non-financial roles56.
Section 177/182: Directors must declare direct or indirect interests in company transactions, even if non-financial26.
Inconsistencies Identified
Conflict of Interest Management
The Companies Act imposes a strict duty on directors to declare all interests that could create conflicts, regardless of financial remuneration26.
The Revised Code’s removal of non-financial interest declarations eliminates a transparency mechanism that helps identify potential conflicts between parliamentary activities and corporate roles4.
Declaration Thresholds
Under the Companies Act, directors must declare interests if they “might reasonably be thought to influence” their actions26. This includes indirect interests (e.g., family members’ roles)6.
The Revised Code’s narrower focus on “relevant financial interests” creates a loophole where non-financial directorships (e.g., in law reporting bodies or charities) might not be disclosed, despite their potential to influence parliamentary work4.
Enforcement Gaps
The Companies Act requires declarations to be made as soon as practicable and updated if incomplete2.
The Revised Code’s deletion of Category 10 removes a critical compliance tool for tracking non-financial roles, increasing the risk of inadvertent breaches of Companies Act duties4.
Legal Risks
Breach of Section 175/177: A member of the House of Lords who is also a company director could fail to declare a non-financial interest (e.g., an unremunerated directorship) that influences parliamentary actions, violating their duty to avoid conflicts under the Companies Act46.
Public Perception: The Companies Act’s “reasonable person” test for conflicts (§14 of the Code1) is broader than the Revised Code’s financial focus. This discrepancy risks undermining public trust in parliamentary integrity4.
Conclusion
The Revised Code of Conduct introduces a regulatory misalignment with the Companies Act 2006. By exempting non-financial interests from declaration, it weakens transparency mechanisms designed to prevent conflicts of interest, thereby increasing the risk of inadvertent breaches of directors’ statutory duties. While the Code’s aim to reduce administrative burdens is understandable, the changes may inadvertently create legal vulnerabilities for members who hold corporate roles. A legal review of the Revised Code’s compatibility with the Companies Act is advisable to address these gaps46.
1b. Commissioner’s dismissal letter 6 May 2025 (pages 35-43).
“RE: Complaint Lord Hermer fails to declare Matrix Chambers and The Harbour Foundation
To: alisonwright45@btinternet.com;
06/05/2025 10:18
Dear Ms Wright,
The Commissioners for Standards previously stated to you in their letters dated 17 April:
“Should my office receive any further complaints from you which include allegations regarding the Companies Act 2006 or members’ identities on Companies House, we as Commissioners for Standards reserve the right to treat such a complaint as vexatious and to dismiss it in its entirety, regardless of any other allegations it may contain.”
The Companies Act 2006 and members’ identities on Companies House are outside the Commissioners’ remit. The guidance above has been issued to you repeatedly, and to date it has not been heeded.
Your complaint makes allegations regarding the Companies Act 2006 and a member’s identity on Companies House. Therefore, the Commissioner considers that your complaint is vexatious and is dismissing it in its entirety regardless of any other allegations included.
Best wishes,
Office for the Commissioners for Standards”
1c. Wright to Commissioner - Revised complaint (7 May 2025) pages 31-33.
“To: The House of Lords Commissioner for Standards House of Lords London SW1A 0PW
Date: 7 May 2025
Subject: Formal Complaint – Lord Hermer’s Failure to Declare Directorships Under the Pre-5 April 2025 Code
Dear Commissioner,
I wish to submit a complaint regarding breaches of the House of Lords Code of Conduct (pre-5 April 2025) by Lord Hermer (HM Attorney General), specifically his failure to register directorships in Matrix Chambers Limited and The Harbour Foundation.
Role: Director from 3 March 2016 to 17 February 2021 and 7 October 2023 to 2 August 2024.
Nature of Interest:
Matrix Chambers is a private limited company for “Barristers at law” with active charges to National Westminster Bank PLC, confirming financial activity.
Under the pre-2025 Code, Category 1 required registration of all remunerated directorships, including those where remuneration is paid through associated entities.
Breach: Lord Hermer’s Register of Interests shows no record of these directorships, despite their financial nature and overlapping with his tenure as HM Attorney General.
2. The Harbour Foundation (Category 10: Non-Financial Interests)
Role: Director from 1 March 2017 to 7 July 2024.
Nature of Interest:
As a charitable foundation, this directorship was registrable under Category 10 (non-financial interests) prior to its deletion on 5 April 2025.
Breach: The directorship was active for seven years but never declared in the Register.
Failure to Update the Register
Both roles required registration within one month of appointment or resignation. Lord Hermer’s omissions contravene:
Paragraph 10(a) of the Code: Mandating timely registration of registrable interests.
Paragraph 9: Requiring members to resolve conflicts between personal interests and public duties.
Request for Investigation
I request an investigation into whether Lord Hermer breached the Code by failing to declare these directorships during their active periods.
There are clear precedents for investigating complaints such as mine under the Code of Conduct then prevailing, as the House of Lords Commissioners for Standards have repeatedly upheld complaints regarding failures to declare directorships and relevant interests, including in cases such as Lord Smith of Kelvin, Lord Adonis, and Lord Singh of Wimbledon, where non-registration of directorships or relevant interests led to formal findings of breach and required corrective action.
Yours sincerely, Alison Wright
[address provided]”
1d. Commissioner’s dismissal letter of 16 May 2025 (page 44).
“Ref: 2425-69 16 May 2025
House of Lords London SW1A 0PW lordsstandards@parliament.uk www.parliament.uk/hl-code
Dear Ms Wright,
Thank you for your email of 7 May 2025 concerning the conduct of Lord Hermer. I have conducted a preliminary assessment of your complaint to determine whether it falls within the scope of the Code of Conduct and my remit to investigate.
Your complaint is that Lord Hermer breached the Code of Conduct because of his alleged failure to register two interests.
The Code of Conduct applies to members once they are introduced to the House (paragraph 3 of the Code). Lord Hermer resigned from his role in The Harbour Foundation on 7 July 2024, before he became a member of the House on 18 July 2024. There was therefore no requirement for him to have registered this interest.
Paragraph 16 of the Guide to the Code of Conduct states that new members have one month from taking their seat to register their interests. As Lord Hermer is recorded as having resigned from his role at Matrix Chambers Limited on 2 August 2024, within one month of becoming a member of the House, there was no requirement for him to have registered this interest.
Paragraph 11 of the Enforcement procedure states that the Commissioner will dismiss after a preliminary assessment all complaints “which are unsupported by evidence sufficient to establish a prima facie case that the Code has been breached”. I consider that there is no evidence of a breach in respect of either of these allegations. Therefore, I have dismissed your complaint.
I will also write to Lord Hermer to let him know your complaint has been made but that it will go no further.
Yours sincerely,
Margaret Obi
Commissioner for Standards”
1e. Wright to Commissioner (18 May 2025) (pages 45-52).
“To: Margaret Obi, Commissioner for Standards House of Lords London SW1A 0PW
Date: 18 May 2025
Subject: Request for Reconsideration of Complaint Ref: 2425-69 (Lord Hermer)
Dear Commissioner Obi,
Thank you for your letter of 16 May 2025 regarding my complaint about Lord Hermer’s registration of interests.
I wish to clarify that my complaint concerns Lord Hermer’s declaration of interests upon entering the House of Lords on 18 July 2024, when the 13th Edition of the Code of Conduct (September 2023) was in force. Your response appears to reference the subsequent (14th) Code, but it is the previous Code that governs Lord Hermer’s obligations at the time of his introduction.
Clarification of the Relevant Provisions
Paragraph 17 of the 13th Edition Code states:
“Members are responsible for ensuring that their registered interests are accurate and up-to-date. They should register any change in their relevant interests within one month of the change.”
This paragraph deals with the ongoing obligation to keep the register up to date, but does not address the initial registration requirement for new members.
Paragraph 40 of the Guide to the Code of Conduct (13th Edition) is explicit:
“Members of the House of Lords are required to complete a registration form and submit it to the Registrar of Lords’ Interests within one month of taking their seat.”
This means that all relevant interests held as at the date of entering the House (in this case, 18 July 2024) must be declared within one month of introduction.
Correction of the Interpretation in Your Response
Your letter states:
"Paragraph 16 of the Guide to the Code of Conduct states that new members have one month from taking their seat to register their interests. As Lord Hermer is recorded as having resigned from his role at Matrix Chambers Limited on 2 August 2024, within one month of becoming a member of the House, there was no requirement for him to have registered this interest."
However, this is not an accurate reading of the Code. The statement you attribute to paragraph 16 is actually covered by paragraph 37 in the 14th Edition, which is paragraph 40 in the 13th Edition, quoted above. Paragraph 16 (in the 14th Edition) refers only to the updating of existing registrations after a change occurs.
Treating the one-month period as a grace period in which interests may be omitted if relinquished before registration is not supported by the text of the Code. The plain meaning is that the one-month period is a deadline to declare all interests held at the time of introduction, not a window in which to avoid registration by resigning interests.
Requirement for Late Registration
Paragraph 46 of the Guide to the Code of Conduct (13th Edition), which is applicable in this case, further states:
“46. All interests stay on the Register for one year after the date on which the interest ceased. An interest which is registered late and has already ceased by the time it is disclosed shall however remain on the Register for one year after the date of disclosure.”
If Lord Hermer registers Matrix Chambers Limited late-having held it at the time of his introduction but resigned within the first month-it should remain on the Register for one year after the date of disclosure, ensuring appropriate transparency.
I recognise that changes to the Code of Conduct, including the removal of the provision requiring late-registered interests to remain on the Register for one year after disclosure, fall outside the Commissioner's remit. However, I believe this change weakens transparency and accountability, and I respectfully suggest that the Conduct Committee consider reinstating this important safeguard in future revisions of the Code.
Conclusion
In summary, the Code in force at the time of Lord Hermer’s introduction required him to declare all interests held as at 18 July 2024, including his directorship of Matrix Chambers Limited, within one month. The subsequent resignation of this interest within that month does not negate the obligation to register it. If registered late, it must remain on the Register for one year after disclosure, as per paragraph 46.
I respectfully request that you review your decision in light of these provisions.
Yours sincerely, Alison Wright
References:
Code of Conduct for Members of the House of Lords (13th Edition, September 2023), Paragraphs 17.
Guide to the Code of Conduct (13th Edition, September 2023), Paragraph 40, 46.”
1f. Commissioner to Wright - 22 May 2026 (pages 45-52).
"To: Alison Wright;
22/05/2025 19:30
Dear Ms Wright,
I have passed on your email to the Commissioner, and she has asked me to respond on her behalf.
The Guide to the Code of Conduct requires new members to submit a registration form within one month of taking their seat, it does not specify that their initial registration must account for their interests at the moment of introduction.
The Commissioner’s decision to dismiss your complaint is final and there is no right of appeal.
Kind regards,
Standards Clerk
Journal Office
House of Lords"
2. Registrar of Lords’ Interests’ correspondence (23 May, 13 June, 25 June 2025) pages 54-62.
2a. Wright to Registrar (23 May 2025 at 10.26):
“Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Dear Registrar,
I am writing to request formal clarification regarding the requirements for new members of the House of Lords to register their interests upon taking their seat, specifically under the 13th Edition of the Code of Conduct (September 2023), which governed introductions in July 2024.
Recent correspondence from the Commissioner for Standards’ office has stated that new members are required to submit a registration form within one month of taking their seat, but that the initial registration need not account for interests held at the moment of introduction if those interests are relinquished before the form is submitted. This interpretation appears to treat the one-month period as a grace period, rather than a deadline for declaring all interests held on the date of introduction.
However, paragraph 40 of the Guide to the Code of Conduct (13th Edition) states:
“Members of the House of Lords are required to complete a registration form and submit it to the Registrar of Lords’ Interests within one month of taking their seat.”
A reasonable reading of this provision, in line with the Code’s stated purpose of “openness and accountability” (paragraph 3), is that all relevant interests held as at the date of introduction must be declared within one month, regardless of whether they are resigned during that period. Treating the one-month period as a window in which interests can be omitted by resigning them before registration undermines transparency and creates a significant loophole.
Additionally, paragraph 46 provides that:
“All interests stay on the Register for one year after the date on which the interest ceased. An interest which is registered late and has already ceased by the time it is disclosed shall however remain on the Register for one year after the date of disclosure.”
This further supports the principle that interests held at the time of introduction should be declared, and if registered late, should remain visible for one year after disclosure.
Could you please confirm:
Is it the official position that the initial registration must include all interests held at the date of introduction, even if those interests are resigned within the first month?
If not, could you clarify the rationale and indicate whether the Conduct Committee has considered the transparency risks associated with the alternative interpretation?
I would appreciate your guidance on this point, as it is fundamental to public confidence in the Register and the standards expected of new members.
Thank you for your assistance.
Yours sincerely,
Alison Wright
(Address provided)
References:
House of Lords Code of Conduct (13th Edition, September 2023), Paragraphs 3, 40, 46.
Guide to the Code of Conduct (13th Edition, September 2023).”
2b. Registrar’s first response (23 May 2025 at 13.02):
“From: LORDSREGISTRAR@parliament.uk To: alisonwright45@btinternet.com Cc: LORDSREGISTRAR@parliament.uk Sent: Friday, May 23rd 2025, 13:02
Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
To: Alison Wright;
23/05/2025 13:02
Dear Ms Wright,
Thank you for your email.
As you state, these matters were raised by you in correspondence with the Commissioner for Standards following a complaint you made. It would not be appropriate for me to second-guess the commissioner, so I do not wish to add to what the commissioner wrote to you.
Yours sincerely,
Nicolas Besly
Registrar of Lords’ Interests"
2c. Wright to Registrar (23 May 2025 at 13.19):
“Re: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
To: Lords Registrar;
23/05/2025 13:19
Dear Mr Besly,
Thank you for your prompt reply.
I appreciate that the Commissioner for Standards has ruled on my complaint. However, as Registrar of Lords’ Interests, your published duties include advising members and their staff on their obligations under the Codes of Conduct and providing interpretive guidance on registration requirements, independent of any investigation or complaint1.
Given the significance of this point for the integrity of the Register and the Code’s stated purpose of “openness and accountability,” I am seeking your expert clarification on the following matter of interpretation:
Does the obligation to register interests within one month of taking a seat require new members to declare all interests held at the date of introduction, even if those interests are resigned within the first month?
I am not seeking a review of the Commissioner’s decision, but rather your guidance as Registrar for the benefit of all members and the public. If you feel unable to provide a view, could you please confirm whether you will refer this matter to the Conduct Committee for formal clarification?
Thank you for your attention to this important point.
2d. Registrar’s second response (23 May 2025 at 14.26):
From: LORDSREGISTRAR@parliament.uk To: alisonwright45@btinternet.com Cc: LORDSREGISTRAR@parliament.uk Sent: Friday, May 23rd 2025, 14:26 Subject: RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Dear Ms Wright,
Thank you for your email.
My advice to members and their staff is given in confidence. It is not the role of the registrar to make public pronouncements on how the code of conduct should be interpreted.
Yours sincerely,
Nicolas Besly
2e. Wright to Registrar (23 May 2025 at 18.34):
Re: RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
To: Lords Registrar;
23/05/2025 18:34
Dear Mr Besly,
Thank you for your reply.
I appreciate that advice to individual members is given in confidence. However, the Guide to the Code of Conduct (13th Edition, September 2023) makes clear that the Registrar’s role includes providing interpretive guidance on the Code’s requirements, and that the Registrar “is available to advise members of the House, and may consult the Committee when necessary” (Guide, p. 7). The Guide further states that “a member who acts on the advice of the Registrar in determining what the member is required to register or declare as a relevant interest fully satisfies the requirements of the Code of Conduct as regards registration or declaration” (Guide, p. 8).
Given the public importance of clarity on this point, and the fact that your advice helps set standards for both members and public understanding, I respectfully request that you either:
confirm the general principle that the initial registration should reflect all interests held at the date of introduction (even if resigned within the first month), or
refer this matter to the Conduct Committee for formal clarification, as permitted by your role.
This is not a request for confidential advice, nor for you to comment on the Commissioner’s decision in a specific case, but for clarity on a matter of public and constitutional significance.
Thank you for your attention.
Yours sincerely, Alison Wright.”
2f. Fourth email from Wright to the Registrar of Lords’ Interests (12 June 2025):
Fwd: Re: RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
To: LORDSREGISTRAR@parliament.uk;
12/06/2025 11:02
Dear Mr Besly,
Please will you let me know when I can anticipate a response to the general principle raised below.
Yours sincerely
Alison Wright”
2g. Registrar’s third response (13 June 2025):
“From: LORDSREGISTRAR@parliament.uk To: alisonwright45@btinternet.com Cc: LORDSREGISTRAR@parliament.uk Sent: Friday, June 13th 2025, 10:56 Subject: RE: Re: RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
Dear Ms Wright,
Sorry for the delay in replying to your email of 23 May.
While noting your points I do not think I can usefully add to our previous exchanges. The commissioner has decided on the individual complaint you raised; it would not be appropriate for me to confirm or second-guess that by issuing a general announcement on the matter; and I see no need to refer the matter to the Conduct Committee.
Yours sincerely,
Nicolas Besly”
2h. Wright to Registrar (25 June 2025):
Re: RE: Re: RE: RE: Subject: Request for Clarification: Registration of Interests for New Members Upon Introduction
To: Lords Registrar;
25/06/2025 09:33
Dear Mr Besly,
Thank you for your reply.
I must express my concern that your refusal to clarify the general interpretation of the registration requirements for new members, or to refer the matter to the Conduct Committee, is inconsistent with the duties set out for the Registrar in the Guide to the Code of Conduct (13th Edition, September 2023). The Guide states that the Registrar is to “advise members and their staff on obligations under the Codes of Conduct,” “provide guidance on registration and declaration of interests,” and “consult the Conduct Committee when necessary.”
This is a matter of public importance and of direct relevance to the integrity of the Register. Refusing to provide general guidance or seek clarification from the Conduct Committee, especially where ambiguity exists, risks undermining both member compliance and public confidence in the standards regime.
I respectfully urge you to reconsider your position and either provide the requested general clarification or refer this point to the Conduct Committee for formal consideration.
Yours sincerely, Alison Wright
No response was received to this last communication.
3. Companies House records for Lord Hermer (page 63).
INCORPORATED COUNCIL OF LAW REPORTING FOR ENGLAND AND WALES (THE) (00005034) Company status Active Correspondence address 102 Petty France, London, England, SW1H 9AJ Role Active Director Appointed on 5 July 2024 Nationality British Country of residence England Occupation Lawyer".
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 7 October 2023 Resigned on 2 August 2024 Nationality British Country of residence United Kingdom Occupation Barrister
THE HARBOUR FOUNDATION (00975116) Company status Active Correspondence address 1 Red Place, London, W1K 6PL Role Resigned Director Appointed on 1 March 2017 Resigned on 7 July 2024 Nationality British Country of residence United Kingdom Occupation Barrister
MATRIX CHAMBERS LIMITED (03923287) Company status Active Correspondence address 1 New Change, London, EC4M 9AF Role Resigned Director Appointed on 3 March 2016 Resigned on 17 February 2021 Nationality British Country of residence United Kingdom Occupation Barrister".
4. Pre-2025 Guide to the Code of Conduct (extracts: Paragraphs 40, 46) (page 64)
40. Members of the House of Lords are required to complete a registration form and submit it to the Registrar of Lords’ Interests within one month of taking their seat. Members returning from leave of absence are required to register their interests within one month of their return or, if they have not taken the oath in that Parliament, within one month of taking the oath. It is the responsibility of members to keep their entry up-to-date by notifying changes in their registrable interests within one month of each change occurring. Failure to do so breaches the Code of Conduct. Members are encouraged to correspond with the Registrar by email: lordsregistrar@parliament.uk.
46. All interests stay on the Register for one year after the date on which the interest ceased. An interest which is registered late and has already ceased by the time it is disclosed shall however remain on the Register for one year after the date of disclosure.
