Author: Adrian Ramdat (Director of Training & Consultancy)
July 2025
The Latest IPCO Annual Report: Directed Surveillance and CHIS Activity
In this article, we take a closer look at the areas of directed surveillance and Covert Human Intelligence Sources (CHIS) covered in the latest annual report from the Investigatory Powers Commissioner’s Office (IPCO).
The IPCO Annual Report
Published in May 2025, the latest Annual Report from IPCO reviews inspections conducted throughout 2023. As with every year, the report is approved by the Prime Minister before publication and provides a detailed view of how UK public authorities use surveillance powers, with particular focus on directed surveillance and CHIS activity.
The report identifies progress in compliance but also highlights areas where improvements are still needed, particularly around consistency in operational practice, the quality of risk assessments, and how effectively staff are trained.
Low Usage of Directed Surveillance Outside Policing
One of the standout points from the report is the continued low use of directed surveillance powers by wider public authorities (WPAs) such as local councils and regulatory bodies. Of the 25 WPAs, only 11 had used their powers for directed surveillance or CHIS, with just 462 directed surveillance authorisations issued in total. In contrast, law enforcement agencies (LEAs) issued over 5,000 in the same period.
While the low numbers can reflect a proportionate and careful approach, IPCO notes the downside: infrequent use can lead to a loss of organisational knowledge, poor record-keeping, and an increased likelihood of mistakes when powers are used. This is especially evident in inconsistent or underdeveloped risk assessments.
This is something I often raise when working with organisations. I’m not suggesting these powers should be used unnecessarily, far from it. But using them lawfully and more regularly can help teams become more confident with the legislation and the processes involved.
CHIS Activity: Progress and Ongoing Challenges
The use of CHIS continues to be concentrated in policing and the intelligence community. IPCO found that, overall, standards remain high, particularly in how juvenile and vulnerable individuals are managed. But some challenges remain.
A review of an older CHIS case at MI5 highlighted gaps in record keeping and audit trails. While these issues had largely been addressed, IPCO is keeping the case under review, underlining the importance of robust documentation over time.
In other organisations, IPCO found some risk assessments and authorisations that were too formulaic and lacked detail. Generic or vague documentation undermines accountability and creates ambiguity about what activity is actually being authorised.
Training as a Remedy
Training continues to be one of the most effective tools in improving compliance. Where organisations had invested in regular, structured, and scenario-based training, staff showed a better understanding of legal tests such as necessity and proportionality. These organisations also demonstrated stronger documentation, clearer risk assessments, and a more confident grasp of their responsibilities.
Where things did go wrong, such as vague justifications or poorly articulated authorisations, it was often linked to gaps in training or outdated internal guidance. IPCO is clear that both initial and refresher training are critical to maintaining compliance and operational clarity.
Training as a Preventative Tool
Authorities that had made noticeable improvements had typically done so by updating procedures and pairing them with focused training for authorising officers, legal advisors, and operational staff. This training often addressed:
- Clear alignment between authorised and actual conduct.
- Stronger explanations of necessity and proportionality.
- Better structure and quality in risk assessments.
In these cases, staff were better prepared to identify and manage risk, support CHIS welfare, and issue clearer, more specific authorisations.
IPCO also noted that leadership involvement in training made a clear difference, with internal efforts to build operational understanding helping to embed good practice.
Where CPD was a regular feature, organisations showed a deeper, more lasting commitment to maintaining standards.
The Role of Continuous Professional Development
Beyond structured training, IPCO’s findings also underline the importance of Continuous Professional Development (CPD). While training builds initial knowledge and skills, CPD helps maintain that knowledge over time, supports learning from current practice, and builds resilience across teams.
Organisations that invested in CPD—through seminars, briefings, networks, and external input, were better placed to adapt to changes in legislation, case law, and oversight expectations. CPD also helped staff stay confident, think critically, and embed a positive compliance culture.
A Case for Continued Investment
The report welcomed changes made by the Ministry of Defence, which updated its CHIS policy to ensure that all sources, wherever they are located, now fall under RIPA authorisation. This also allows for the use of Criminal Conduct Authorisations (CCAs) when appropriate, strengthening legal protections and oversight.
IPCO found that CHIS risk assessments in some areas lacked consistency and structure. The message is clear: training must keep pace with policy changes, and CPD helps practitioners make sense of those changes and apply them correctly.
Conclusion: Training and CPD as Strategic Oversight
The latest IPCO annual report leaves no doubt: while most public authorities continue to comply with surveillance legislation, training and CPD remain the cornerstones of good practice. This is especially important for public authorities that seldom use directed surveillance or CHIS powers. Infrequent use increases the risk of non-compliance, and only a strong culture of preparation and learning can mitigate this.
Where training is regular, relevant, and grounded in legal and operational guidance—and where CPD supports ongoing development—compliance improves, risk is better managed, and public trust is upheld.
At The Signature Brand Training & Consultancy, we work with a wide range of organisations to ensure they remain effective and up to date in the RIPA/RIPSA space. In many cases, our support has extended beyond training alone, helping them improve internal processes and, in a number of cases, contributing to better inspection outcomes.
We offer the full range of RIPA/RIPSA training, from general awareness to role-specific sessions for Applicants, Gatekeepers, Authorising Officers and Senior Responsible Officers. Our RIPA Bitesize events are a great option for CPD and cover a variety of areas.
Find out more about how we can help you here: https://thesignaturebrand.co.uk/training/ripa-ripsa-training or contact us at info@thesignaturebrand.co.uk .