Introduction
Part 3 of the Public Services Reform (Scotland) Act 2010 (PSRA) requires the Scottish Government and listed public bodies to publish information after the end of each financial year on steps taken to promote sustainable growth and to improve efficiency, effectiveness and economy. These duties came into force on 1 October 2010 and are intended to support transparency and public accountability.
This report sets out how the Water Industry Commission for Scotland (WICS) has met these requirements during 2024–25. It has been prepared in line with Scottish Government guidance.
Further information on WICS’ work is available on the WICS website. Full audited financial information is contained within the 2024–25 Annual Report and Accounts.
1. Steps to promote sustainable growth
As Scotland’s economic regulator for water, WICS’ ensures that high-quality water and wastewater services are delivered efficiently and sustainably for current and future generations. During 2024–25, WICS published the final methodology for the Strategic Review of Charges 2027–33 (SRC27), which sets the long-term framework for investment, performance and customer charges across the next regulatory period.
The SRC27 methodology embeds sustainability at its core. It strengthens outcome-based regulation, enhances long-term planning, and places greater emphasis on resilience, climate adaptation and evidence-based investment. It enables Scottish Water to plan for net-zero delivery by 2040, while maintaining service quality for customers.
ENABLING SUSTAINABLE ECONOMIC GROWTH
By setting clear regulatory expectations and maintaining a stable investment framework, WICS continued to support sustainable economic growth across Scotland. Through scrutiny of Scottish Water’s costs, performance, and investment plans, WICS ensured that infrastructure investment remained efficient and delivered at reasonable overall cost for households, businesses, and public bodies.
Average household water charges in Scotland remain among the lowest in the UK while sustaining high levels of investment.
STRENGTHENING THE NON-HOUSEHOLD RETAIL MARKET
WICS took further steps to promote sustainable growth in the competitive non-household water retail market. A new market-wide Code of Practice was developed collaboratively with licensed providers, Consumer Scotland, Scottish Water and the Central Market Agency. This sets clear service standards that go beyond minimum licence conditions and strengthens customer confidence.
In parallel, WICS introduced the Market Health Check, an independent assurance process allowing retailers to demonstrate they are delivering these enhanced service standards. These measures support a fair, competitive and sustainable retail market that delivers tangible benefits for business customers.
KNOWLEDGE SHARING AND INTERNATIONAL ENGAGEMENT
During 2024–25, WICS refocused its international engagement to support its domestic regulatory priorities. Revenue-generating international consultancy was paused in line with Scottish Government direction. However, WICS continued to contribute to global regulatory learning through networks such as the OECD Network of Economic Regulators, and by sharing Scotland’s regulatory experience with international partners through targeted knowledge-exchange activity. This ensures that Scottish regulation continues to benefit from international best practice while maintaining a clear focus on domestic sustainability and value for customers.
2. Steps to improve efficiency, effectiveness and economy
During 2024–25, WICS delivered a wide-ranging programme of organisational reform in response to the Section 22 report and subsequent parliamentary scrutiny. A revised governance framework and updated Scheme of Delegation were implemented, clearly defining the respective roles of the Board, the Chief Executive and the Executive leadership team.
Financial controls were significantly strengthened through revised financial, procurement, expenses, training and fraud policies. Cross-functional approval processes were introduced for significant expenditure, and compliance reporting to the Board and Audit and Risk Committee was enhanced. Internal audit providers and Audit Scotland both acknowledged substantial improvements in governance and control arrangements during the year.
DELIVERING VALUE FOR MONEY
WICS restructured its senior leadership into four directorates, creating a smaller and more accountable senior team. Executive pay was realigned with public sector benchmarks, delivering recurring savings that were reinvested into building internal capability and reducing reliance on consultants. Key regulatory work, including the SRC27 methodology, was delivered entirely in-house. The use of Scottish Government procurement frameworks for IT, professional services and support functions reduced overheads while maintaining service quality.
SHARED SERVICES, ACCOMMODATION AND DIGITAL EFFICIENCY
WICS adopted wider shared services arrangements during the year, including shared accommodation. This supported better use of public assets and reduced operating costs. IT systems were further optimised following earlier migration to cloud-based infrastructure, delivering ongoing annual savings while maintaining cyber resilience. Hybrid working was embedded as the standard operating model, supporting staff wellbeing while reducing travel, accommodation and estate costs.
CYBER RESILIENCE AND RISK MANAGEMENT
Cybersecurity remained a key organisational priority. WICS successfully renewed its Cyber Essentials Plus accreditation, strengthened Board-level oversight of cyber risk, and delivered mandatory cyber awareness training for all staff and Board members. A revised risk management framework was introduced, aligned with the organisation’s strategic objectives. This strengthened WICS’ ability to identify, monitor, and mitigate financial, operational, regulatory, and reputational risks in a proportionate and structured manner.
TRANSPARENCY, ACCOUNTABILITY AND ASSURANCE
WICS actively engaged with Audit Scotland, the Public Audit Committee and the Scottish Government throughout the year. It supported the Scottish Government’s independent review and responded transparently to parliamentary scrutiny. Whistleblowing arrangements were strengthened internally and externally. One external whistleblowing report relating to Scottish Water was investigated during the year and closed following a full independent review. WICS continued to publish regulatory reports, performance assessments and consultation materials openly, reinforcing its commitment to transparency and public accountability.
3. Expenditure information
All expenditures disclosed in the sections below include VAT, as WICS is not VAT registered.
3.1 Public relations
WICS must publish a statement of expenditure during the year on all external communications, including the cost of in-house and contracted staff and consultants. Expenditure on 'public relations' includes (for example) marketing, PR campaigns, media relations, marketing research and evaluation, branding and design, promotional events, external events, conferences and exhibitions, corporate communications, sponsorship, publications and printing, digital communications, advertising and media planning. The following categories of expenditure incurred by WICS relate to public relations:
Expenditure type |
2024-25 (£) |
2023-24 (£) |
| External media support | 48,720 | 26,220 |
| Website hosting | 6,486 | 4,633 |
| Website development and maintenance | 18,506 | 19,106 |
No employees at WICS have been explicitly employed to perform a role in any of these areas.
3.2 Overseas travel
WICS is required to publish a statement of expenditures incurred on overseas travel, including travel to and from the United Kingdom. The following should be included: the cost of hotels, conference fees, travel and subsistence during the overseas visit, and any other related expenditures.
Type of expense |
2024-25 (£) |
2023-24 (£) |
| Flights | 211 | 35,235 |
| Accommodation | 586 | 11,672 |
| Subsistence | 24 | 16,646 |
| Other travel and expenses | 17 | 7,770 |
3.3 Hospitality and entertainment
WICS is required to publish a statement of expenditure on hospitality and entertainment, which is widely interpreted as including any gifts, meals, parties, receptions, tickets for or invitations to public, sporting, cultural or other events or other similar benefits accorded by a public body to its own members, employees, or third parties for whatever reason.
The payment of reasonable travel and subsistence allowances and the reimbursement of expenses that are necessarily incurred in relation to service as a member or employee of a public body are excluded. Gifts and benefits which are wholly trivial and of minimal value are also excluded as de minimis. WICS has disclosed gifts over £50 for 'one-off' gifts or benefits.
Meals and Events |
||
Type of expense |
2024-25 (£) |
2023-24 (£) |
| Staff related | - | 559 |
| Stakeholder related | - | 1,791 |
Gifts > £50 |
||
Recipient |
2024-25 (£) |
2023-24 (£) |
| WICS employees and members | - | 105 |
| External stakeholders | - | 192 |
3.4 External consultancy
WICS must provide a statement on expenditures on “external consultancy” services, which are defined as a wide range of professional services such as management consultancy, IT consultancy, financial consultancy, research and evaluation, and policy development. WICS requires wide-ranging advice to make appropriate assumptions about the reasonable costs it should allow in setting prices. These assumptions must be robust to external challenges. WICS must also ensure that its processes and decisions can withstand judicial scrutiny. Supplementing WICS’ expertise with that of outside experts provides significant reassurance of the quality and independence of its work. As WICS is a small organisation with fewer than 25 employees, it requires the services of external experts for activities such as HR and data protection. The cost of these external experts is considered to be better value for money than employing individuals to fill these roles. Expenditure on external consultancy services is outlined by type in the table below.
Type of consultancy service |
2024-25 (£) |
2023-24 (£) |
| Regulation and licensing support | 213,408 | 297,391 |
| Internal audit and accounting | 52,430 | 90,588 |
| Data protection services | 31,481 | 15,743 |
| HR and recruitment | 63,494 | 40,085 |
| Information and technology | 19,391 | 26,530 |
| Other | 13,443 | 9,260 |
3.5 Payments in excess of £25,000
Section 31 (3) of the Act provides that each listed body must publish a statement specifying the amount, date, payee and subject matter of any payment made with a value in excess of £25,000 (inclusive of VAT). The table below provides information on all payments made by WICS over £25,000.
Date of transaction |
Amount (£) |
Recipient |
Description |
| 12/04/24 | 25,048.50 | Stirling Council | Office rent, Moray House, Stirling |
| 12/06/24 | 26,175.60 | Stirling Council | Office rent, Moray House, Stirling |
| 21/08/24 | 26,175.60 | Stirling Council | Office rent, Moray House, Stirling |
| 12/09/24 | 48,000.00 | Grant Thornton | Internal audit services |
| 12/09/24 | 30,808.00 | Water Research Centre | Engineering services |
| 04/12/24 | 26,175.60 | Stirling Council | Office rent, Moray House, Stirling |
| 18/12/25 | 47,397.00 | Water Research Centre | Engineering services |
| 12/03/25 | 26,175.60 | Stirling Council | Office rent, Moray House, Stirling |
3.6 Remuneration
Section 31(4) of the PSRA provides that each listed public body must publish a statement specifying the number of individuals (if any) who received remuneration during that financial year in excess of £150,000 in relation to service as a member or employee of a public body. Remuneration in relation to service as a member or employee includes salary, bonus or other discretionary performance payments, allowances, fees, royalties, and bonus or other payments in respect of performance in a previous financial year, but it does not include receipt of a pension, voluntary severance, compromise agreements, or redundancy payments.
No employees of WICS received remuneration payments in excess of £150,000 during the financial year 2024-25.
WICS' annual report and financial statements fully disclose remuneration costs, directors’ salaries, and pension entitlements.