Interview: Tim Moss, Companies House

Civil servants taking the train from Paddington to visit the Cardiff headquarters of Companies House leave behind the manic whirl of Whitehall for a far more laid-back capital. In overcrowded, fast-moving London, many officials’ working lives are kept at a constant boil by incessant political, policy and organisational change – and trapped in a pressure cooker of impatient ministers, harried permanent secretaries and excitable journalists. But as visitors alight at Cardiff Central, that pressure is released.

In the Welsh capital, the traffic is light, the streets relaxed, the space plentiful. And the HQ of Companies House (CH), a mile or so north of the city centre, is – at least on the day of my visit – a hushed and sparsely-populated place, where the receptionists offer me an effusive welcome before kicking back to banter with a gang of passing building contractors. By the time I’ve had a coffee in the boardroom, I’ve slowed from London’s madcap rush to a far more civilised pace.

Then CH chief executive Tim Moss walks into the room, and suddenly we’re back up at 90mph – for Moss is a barely-contained bundle of energy, words tumbling out of him at breakneck speed. He’s spent 20 years in Wales – and lives on a working farm with his in-laws, occasionally herding sheep and cows on a weekend – but interviewing this grammar school boy from Barnet is like trying to engage a machine-gun emplacement with a bolt-action .303. To be fair, though, he does keep a sensitive ear out for incoming fire – and the first thing I want to talk about is staff morale.

Between the 2011 and 2012 Civil Service People Surveys, CH recorded a 13-point rise in the ‘leadership and managing change’ category and a 12-point rise in ‘learning and development’. The proportion of staff expressing confidence in the senior leadership team rose by 18 points; those saying the board has a clear vision for the future by 13 points; and those believing that CH is well managed by 15 points. What’s more, even in 2011 most of these metrics sat around the civil service average: CH’s engagement score is now 63%, putting it near the top of the organisational rankings.

Reasons to be cheerful
Asked how he has produced these results, Moss fires back that he and his senior team have concentrated on “getting out there and saying: ‘This is what we’re about; this is where we want to take the organisation,’ and giving people an opportunity to ask questions and contribute”.

Every six months, the agency’s leaders take the entire 880-strong staff through the business plan in small groups, emphasising their own accountability and their commitment to the wellbeing of both customers and staff. It is, he adds, “really important that people understand what our aims as an organisation mean for them in their team.” Employees must also understand how their roles contribute to the organisation’s work – and how this, in turn, plays a key role in supporting the UK economy.

CH’s role is to receive data on registered companies – such as the names of directors and the company accounts – and make it available. “The UK is number one in the World Bank’s ‘Doing Business’ report on credit, and a lot of that stems from the transparency in corporate information, which we underpin,” Moss explains. CH data supports a vast range of business services in credit reports, risk analysis and investment advice, though Moss emphasises that CH is “a register, not a regulator”: rather than verifying or processing the information it receives, its role is to make it available to the public “as quickly and easily as possible”.

Like every other part of the civil service, CH has seen a spending squeeze in recent years: while its 2011 staff survey results weren’t bad, Moss concedes they’d been depressed by changes including an office closure. Yet the agency faces a demanding set of service delivery reforms and improvements – and when Moss became interim chief executive in March 2012, he brought to the job a belief they would only be achieved if the agency’s staff were first motivated, then drawn into an ambitious ‘continuous improvement’ programme. “This is not to decry the previous senior team, but one of the things I really wanted to look at was how we could improve engagement,” he says. Addressing the challenges faced by CH will mean “getting everybody on board. It’s not about me telling them what to do: it’s about getting everyone involved in saying: ‘How do we achieve our ultimate goals?’”

Handing over the controls
As Moss explains, continuous improvement – or ‘Lean’ management – involves “engaging with your staff to get them to look at what we do; then change it and own the process; and then keep on making things better.” So he concentrated on building that staff buy-in, before having his senior managers trained in Lean techniques: they then “trained others internally, so it’s been our own staff helping others to do it,” he explains. “We’ve taken a long-term approach and used our own people; this is not about getting consultants in and spending lots of money to review your processes.”

Moss believes that the Lean programme lies behind the substantial rise in the CH’s People Survey scores on the ‘learning and development’ theme (though from its low starting point, the 12-point increase only brings the organisation up to the civil service average). From the sound of it, the introduction of Civil Service Learning – the single cross-government training portal – has not been received as well: “I think we’re starting to see some of the benefits now and how it fits in,” he comments. “Change like that is always difficult, from having complete control and doing your own thing to fitting into central contracts – does it really fit your needs? But we’re now working through that.”

Balancing acts
The continuous improvement programme raised efficiency, further boosted staff engagement, and improved customer service: the number of complaints fell by more than half between 2010-11 and 2011-12. Indeed, Moss is intensely aware of the need to provide companies with a good service – so you might expect him to be a fan of the Red Tape Challenge, designed to reduce the regulatory burdens on business.

Yet he points to a tension here: the data submission requirements placed on companies by CH, he argues, exist to create a safe and transparent business environment, and rather than prioritising a reduction in the number of regulations we should concentrate on making it easier to comply with the rules. “You can cut burdens tomorrow, but it’ll be at the price of transparency,” he says. “If you got rid of [the requirement to] file accounts, that would have a huge impact on the business information market, and would be counterproductive for the economy. So the emphasis has to be on how we can make it simpler and easier for people to file their accounts with us.”

Because the Red Tape Challenge measures its success by the number of regulations removed, Moss suggests, it can distort people’s priorities as they work to lighten the burden of regulation. “There can be a requirement saying: ‘We’ve got 50 bits of legislation. How can we get it down to 30?’” he comments – but there are two sides to cutting red tape: “Can you reduce the number of things that people need to comply with? But also, can you make it a lot easier for people to do what they need to do? And from our point of view, a lot of what we do fits into the second category. That doesn’t always count in your ‘one-in-one-out’ discussions, but actually for the real customer can be just as important.” Digital technologies, he adds, offer big opportunities to “give quicker, easier access to the data, but at less burden to the companies and at lower cost” – and this prize is “just as important, if not more important, than how many bits of legislation there are.”

If Moss resists some of the ambitions of the deregulatory Red Tape Challenge, however, he’s just as sceptical about ideas that involve increasing the regulatory burden. In a report published last November the Fraud Advisory Panel made a series of recommendations, including “Introduce new minimum due diligence checks at Companies House on all new directors to existing companies against the Disqualified Directors Register”, and “Introduce a fit and proper persons test for all new company directors to confirm their identity and demonstrate their good character.” But Moss is clear that implementing such ideas would make it much more complex, expensive and time-consuming to alter the register, “placing considerably higher burdens on those supplying the data or the costs of running that system, and slowing down how quickly that information can be out in the public domain.” (See news)

Take the idea of introducing a ‘fit and proper person test’ for all new directors, he says: building an effective system to enforce that would be “nigh-on impossible”. After all, not all companies are traditional trading businesses: in many cases, people buying leasehold properties automatically become directors in their block’s flat management company. “Do you stop them from buying the flat because they don’t pass a fit and proper person test? And if you don’t apply the rule in that instance, what are the other exceptions?” With the register currently holding more than three million companies, he says, “you’d need a highly robust system to take account of the myriad of different circumstances; or you’re into the realm of trying to make very detailed judgements about individual circumstances, and then you need a lot of information.”

CH, Moss explains, doesn’t have the powers or remit to verify data it receives: its role is to collect and publish data. “Now, does that allow fraud to occur? Yes, it does. But it also enables huge benefits about being able to set up a business quickly and easily.” In his view, the best answer is to move on two fronts. First, digital technologies can produce “solutions that enable you to keep the benefits of the system while reducing the opportunities for fraud”: he cites a new CH system that enables companies to control their register entries via a secure online system, reducing the opportunities for fraudsters to take over their corporate identities by submitting paper documents. And second, CH needs to work more closely with partners such as the courts and the Insolvency Service, developing “a more reactive enforcement regime” so that when fraud does occur it’s tackled swiftly and effectively.

Digital dreams
It’s notable that Moss’s response to both agendas – both the regulatory and the deregulatory ones – is to suggest that digital technologies can provide a different way to address the problem. In the long term, he believes, public services can be made more accessible and compliance requirements less onerous by giving many companies a single, cross-government online account. “You have an Amazon account that enables you to deal with multiple retailers,” he says. “Can you have a ‘my account’ with government that minimises the burden?”

Such a project would, he adds, take government bodies “out of the nice comfort zone of being an organisation on your own, and ask how you interface with others. Some of this is really difficult stuff, but we’re keen to work with Government Digital Service [GDS] and HMRC and others to work out a long-term vision, and to work towards it.”

In Moss’s view, pursuing this kind of long-term vision will be made easier by the fact that CH owns its own IT infrastructure: indeed, it’s just bought five new servers, deciding against outsourced alternatives such as cloud storage. “Our IT equipment is not a support service; it’s frontline delivery,” he says. “And we have huge benefits from doing a lot of our IT and development work in-house: it gives us the ability to respond to the needs of customers and develop our services quickly and easily.” He cites the example of some CH staff who developed a mobile app: “Three months later, we’ve launched it. Now we’ve had 40,000 downloads, and it cost us less than £20,000.”

With control of its own IT staff and facilities, CH isn’t tied into restrictive supplier contracts and can make full use of its continuous improvement programme, Moss argues. “Having in-house development means that we can change priorities quickly,” he says. “We certainly wouldn’t swap it.”

As CH develops its online services, he adds, it is working towards providing a single customer interface – replacing the wide variety of datastreams by which people can receive information from the register. This, he explains, will support the open data agenda by driving down the cost of supplying information: CH is barred from cross-subsidising its information services from the fees paid by its company customers, so its data release operations must be self-funding.

A very diverse group
Asked about the Public Data Group – in which CH now sits, alongside the Met Office, Ordnance Survey and the Land Registry – Moss says many of its strengths lie in its members’ diversity rather than their commonalities. “There are some questions about why these four organisations are thrown together. What do weather and companies have in common?”, he asks, adding that the benefits so far have come not from “mashing big sets of data together” but from the organisations’ specialist officials sharing ideas, techniques and technologies.

The PDG’s members employ two very different business models, he adds – the Met Office and OS process data to sell it on, while the Land Registry and CH charge statutory fees to customer groups to gather and publish datasets – so “you’ve got four different perspectives” within the group. But from CH’s standpoint, Moss says a decision is required as to whether the government wants to radically increase the amount of data that it publishes free of charge – something requiring “a different funding model” to pay for its data releases – or would rather “get a return on the asset and maximise value.”

The Shareholder Executive has recently signalled its interest in privatising some of the data-rich trading funds – in which case, it will have an interest in getting the greatest possible return: the valuable Postal Address File is, after all, likely to be included in the sale of Royal Mail. But Moss argues that a privatisation would be unlikely to produce a better service for customers, or to yield big improvements in value for money: “We’ve got a good track record on efficiency,” he says.

The other possible reason for selling up would be to cash in on CH’s data assets, but unless there’s the potential to radically improve efficiency then CH’s market value would be largely decided by the government’s readiness to allow a private operator to increase the charges to register changes or access data – something that would produce another drag on businesses. “Is there an aim to make money out of the register, or is it part of the national data infrastructure and should therefore be free?” asks Moss.

Like the tensions between the Red Tape Challenge and transparency in business information, or those between the anti-fraud and deregulatory agendas, the dissonance between the government’s open data policies and its need to sweat its assets can ultimately only be resolved by politicians – and whichever way the government jumps, some of its ministers and officials will find their projects undermined.

These are big decisions for the government, and Moss has just submitted a strategic review of CH’s future to business minister Michael Fallon. This, he says, asks some important questions about the organisation’s long-term aims, and “puts some options to ministers about free data or charging.” But, at least as far as the privatisation debate goes, it’s pretty clear where Moss stands. “We believe that we have a public task,” he says. “And we’ve been going about making it easier and cheaper to access information on the register, so that people can make decisions and add value to the information – and benefit the economy that way.”