Police modernisation: what forces can do now to prepare

The Government's From Local to National: A New Model for Policing White Paper sets out a significant programme of reform, including fewer, larger forces, a new National Police Service, changes to local policing and revised governance arrangements. The Independent Review of Police Force Structures, chaired by Lord Hogan-Howe, is expected to report before the end of November. Important details remain subject to legislation and implementation planning, but the pace of change means forces cannot afford to wait.

For in-house employment lawyers, senior HR professionals and police leaders, the priority is to understand the workforce implications early, identify the decisions that may create legal or operational risk, and ensure employment considerations inform the transformation programme from the outset.

Six steps to take now

1. Establish a clear workforce baseline

Build a reliable picture of the current workforce, including roles, reporting lines, locations, contracts, pay and allowances, working patterns, policies, vacancies, restrictions and employee relations issues. Identify differences between forces and functions that could become significant if structures are combined. For police officers and police staff, distinguish carefully between their respective legal status, employment frameworks and applicable transfer arrangements.

2. Identify the legal and contractual issues before designing the new structure

Map the potential implications of mergers, shared services, national functions and changes to local policing. Review contractual mobility provisions, location-based arrangements, collective agreements, pension considerations and existing liabilities. Do not assume that TUPE will apply automatically, or that existing terms can simply be harmonised. The legal route will depend on the functions being transferred, the organisations involved and the arrangements ultimately adopted.

For example, a force merging with a neighbour may find that existing location-based contractual provisions prevent the redeployment of staff, or that pay harmonisation is constrained by collectively bargained agreements. Getting ahead of these issues now is far less costly than managing them under time pressure. Forces should also note that the Hogan-Howe Review's terms of reference include identifying which forces are best suited to form part of pathfinder mergers this Parliament – meaning specific forces could be selected for early merger well ahead of the wider programme. For those forces, the timeline will be materially shorter.

3. Plan for the Licence to Practise

The White Paper introduces a Licence to Practise for police officers, who will be required to hold and renew the licence throughout their career. Officers who fail to reach the required standard, following opportunities to try again, will be removed from the profession. This creates novel workforce and employment law questions that forces should begin to work through now: What processes will govern non-renewal? How will the licence interact with existing capability and misconduct frameworks? What redeployment, reasonable adjustment or appeal obligations may arise? The Government has acknowledged it will not be able to introduce the licence immediately and will consult extensively on implementation. Forces should use that window to review current development and training infrastructure, assess capacity constraints and consider how the licence framework will be embedded in workforce planning.

4. Prepare for the abolition of PCCs

Police and Crime Commissioners are to be abolished, with the transition confirmed for May 2028. In most areas, PCC roles and functions will be absorbed by regional mayors; in areas not covered by a mayor, the role will pass to elected council leaders. This creates a significant set of employment and TUPE-adjacent questions for PCC statutory office holders, office staff and for functions currently commissioned or employed through PCC structures. Forces should map their PCC-related workforce now, identify the individuals and functions affected, and begin to assess the transfer, redundancy and harmonisation implications before the 2028 deadline compresses the timeline.

5. Address vetting and the new mandatory standards

The White Paper commits to introducing mandatory vetting standards for all forces, enabling forces to exclude those with a caution or conviction for violence against women and girls offences from policing. Stronger requirements on forces to suspend officers who are under investigation for these offences will also be introduced. Forces should review current vetting processes, decision-making frameworks and suspension protocols now. The employment law dimensions – including the interaction with misconduct procedures, the risk of challenge to vetting decisions, and obligations around fairness and consistency – will require careful governance as the mandatory standards are implemented.

6. Engage workforce representatives early, communicate with staff and put governance around the transition

Develop a plan for engagement with recognised unions, staff associations and other relevant representatives. Understand where changes may affect jobs, locations, working arrangements or established practices. Early, credible engagement can help identify practical obstacles, test proposals and reduce the risk of disputes. Formal consultation obligations and timescales should be assessed as specific proposals develop.

Forces should also recognise that the scale and pace of the reform programme is already generating real concern and uncertainty among officers and staff. Questions about potential redundancy, redeployment and changes to working arrangements are understandable, and uncertainty left unaddressed can affect morale, retention and operational performance. A proactive internal communications strategy – keeping the workforce informed of what is known, what is still to be decided and what the force is doing to protect their interests – is not simply good management practice; it is a material part of managing workforce risk through a period of significant change.

Alongside this, establish clear ownership of workforce risks, decision-making responsibilities and escalation routes. Create an employment law risk register, agree key decision points and build legal input into the transformation timetable. Keep assumptions separate from confirmed decisions and review the plan as the Police Reform Bill progresses and implementation arrangements develop. Consider also how leadership structures, specialist capabilities, career pathways and support functions may evolve – and ensure that equality, flexible working, wellbeing, and the workforce impact of technology and AI are addressed as part of the programme, not as afterthoughts.

How TLT can help

TLT has advised forces on employment and workforce matters within the National Legal Services Framework and has been active in commentary on the reform programme since the White Paper's publication. We can work alongside your in-house legal, HR and transformation teams to turn the emerging reform proposals into a practical, prioritised programme of work.

Support could include a workforce legal readiness review to identify material risks and information gaps; a merger and restructuring employment roadmap covering transfers, consultation, contractual issues and workforce integration; and targeted advice on complex employee relations, collective engagement, equality, reward, pensions and organisational change. We can also advise specifically on Licence to Practise implementation planning, PCC abolition workforce implications, and mandatory vetting standard changes.

We can also help develop decision-making frameworks, brief senior leaders and HR teams, and provide ongoing support as proposals move from planning into implementation.

The objective is not to anticipate every final decision. It is to ensure that, when those decisions arrive, your force has the evidence, governance and legal preparation needed to act confidently, protect workforce relationships and maintain operational continuity.

The opportunity now is to prepare early, preserve flexibility and make workforce considerations central to successful modernisation.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at November 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.