Tonbridge & Malling Borough Council’s Audit Committee considered a risk register update on 28 September 2026 showing that failure to adopt a local plan is the only remaining top-level risk after the government directed the council to continue plan-making despite a vote to pause it.
The failure to adopt a local plan remains the only risk rated ‘red’ on Tonbridge & Malling Borough Council’s Strategic Risk Register, following a sequence of events in early September 2026 in which the council voted to pause plan-making only for the government to intervene and direct it to continue.
What happened with the local plan
According to papers presented to the Audit Committee on 28 September 2026, the council voted on 3 September 2026 to pause work on its local plan under the current legislative and National Planning Policy Framework (NPPF) transitional arrangements. However, the Ministry of Housing, Communities and Local Government (MHCLG) wrote to the council on 4 September 2026 to intervene in the process and direct it to progress with plan-making through a Regulation 19 consultation, plan submission and examination. The council wrote to the Minister on 11 September 2026 to set out what it described as the exceptional circumstances that had informed its decision to pause.
Officers reported that, following the council’s vote and the government’s subsequent intervention, the Management Team considered the risk of final adoption of the local plan to remain high. The risk is scored at 15 out of 25 after mitigation — the threshold for a red rating — with an unmitigated score of 20. The risk has been on the register since April 2017 and is owned by the Director of Planning, Housing and Regulatory Services.
The papers noted that detailed discussions are ongoing with statutory providers, MHCLG and the Planning Inspectorate (PINs) to ensure any required mitigation measures are in place. Actions listed to reduce the risk further include regular review of NPPF guidance, continued engagement with members and the public, ensuring sufficient staffing and financial resources, and ongoing lobbying of MHCLG officials and ministers.
Local government reorganisation risk downgraded
A second risk that had been rated red at the committee’s July meeting — local government reorganisation in Kent — was downgraded following an announcement earlier in September 2026 to pause the reorganisation process for Kent authorities. Officers said that while the impact of reorganisation remains at a heightened level, the announced pause had reduced the likelihood, resulting in the overall score falling below the red threshold.
Risk strategy update
The committee was also asked to review an updated Risk Management Strategy and accompanying guidance, which officers recommended for adoption by Full Council. The updated strategy includes a new section on risk appetite — defined in the papers as the total amount of risk an organisation is willing to accept while attempting to reach a goal — following recommendations from an Internal Audit review of risk management carried out in the summer of 2025 and a follow-up in the summer of 2026. If approved, the strategy and guidance were to be passed to Full Council for adoption in October 2026.
The council had not published the minutes of the meeting at the time of writing, so the committee’s decision is not yet on the public record.
Sources
- Tonbridge & Malling Borough Council — Audit Committee, 28 September 2026 (agenda and papers)
- Risk Management Report — Management Team report to Audit Committee, 28 September 2026 (Tonbridge & Malling Borough Council)
- Annex 1: Strategic Risk Register — Red Risks, September 2026 (Tonbridge & Malling Borough Council)
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