What does merging public bodies actually achieve?
There is a peculiar ritual in government reform. A government announces that several public bodies will be merged, promises this will make the state more efficient and save money, and everyone moves on to the next announcement.
The details come later.
That is essentially what is happening with the Scottish Government’s plan to bring together the Scottish Environment Protection Agency, NatureScot, and Zero Waste Scotland into a single environmental body, with Scottish Forestry potentially joining them too. The new organisation is expected to be in place by 2029.
There is nothing inherently wrong with merging public bodies. Organisations can have overlapping functions, duplicated administration, or structures that no longer make sense. Sometimes bringing organisations together genuinely improves coordination or reduces costs.
The problem is the ease with which merger has become synonymous with efficiency.
The Scottish Government has presented the new body as a way of delivering greater efficiencies while bringing together the expertise and authority of the existing organisations. That may happen. But the case currently appears to rest more heavily on the assumption that merging organisations will produce savings than on evidence showing what those savings will actually be.
When Gillian Martin appeared before Holyrood’s committee in September, she could not give a firm timetable for recruiting the new board or chief executive. The remit of the shadow board was still being worked out, while the Government had given the organisations only a broad indication of 2029 for the new body. MSPs also raised concerns about execution risks and disruption to the existing organisations.
The obvious response is that this is still early in the process. But that raises another question: why is the Government so confident that a merger will deliver efficiencies before establishing what it will cost, how it will work, or how those efficiencies will be measured?
This is not a hypothetical concern. The National Audit Office has been documenting the problem for years.
Its guidance on government reorganisations is straightforward: mergers can deliver benefits, but only when governments are clear about the outcomes they want, plan implementation realistically, protect operational delivery, and systematically track costs and benefits. It warns that risks increase when structural changes are implemented without clear objectives or a proper understanding of the resources required.
That is the difference between reform and rearrangement.
The NAO has previously found that governments were poor at identifying the costs and benefits of reorganisations. In one review of more than 90 reorganisations, more than half did not compare the expected costs and benefits of the chosen approach against alternatives. Departments also frequently failed to establish measures that would demonstrate whether promised benefits had actually materialised.
The costs of changing an organisational chart are real. Staff have to be moved, IT systems integrated, management structures redesigned, and organisational cultures brought together. The NAO has identified costs including recruitment and redundancy, IT, property, consultancy, staff time, and lost productivity or institutional knowledge during disruptive reorganisations.
Even where a merger produces genuine efficiencies, that does not mean those efficiencies automatically become savings to the public.
The merger that created the Foreign, Commonwealth and Development Office did produce some benefits, according to the NAO. But the department did not systematically track those benefits and did not know the full cost of the merger. It spent at least £24.7 million on the process before indirect costs such as disruption and diverted staff time were included. The NAO concluded that without clearer tracking of costs and benefits, the merger’s value for money could not be assessed.
This is why the Government needs to stop treating the number of public bodies as a proxy for the efficiency of the state.
Three organisations becoming one does not mean three sets of work become one. Environmental regulation, nature protection, waste management, and forestry involve different expertise and responsibilities. Bringing them together might make some things easier. It might make others more complicated. The only way to know is to establish what problem the merger is intended to solve and measure whether it actually solves it.
Otherwise, “efficiency” becomes a magic word: it sounds like an outcome without requiring anyone to define the outcome.
There is an important difference between wanting a smaller public sector and wanting a public sector that works. A government can reduce the number of boards, chief executives, and logos while leaving the same work to be done. It can even spend considerable sums doing so.
Scotland should therefore ask a more basic question than how many public bodies it has. What does each organisation exist to do, what is not working, and what evidence shows that changing its structure will make it work better?
If the Scottish Government believes this merger will save money, it should say how much it expects to save, how much the transition will cost, what services might be affected, and how it will determine whether the promised benefits actually materialise.
Otherwise, we are not being offered public-sector reform. We are being offered an organisational chart with fewer boxes. And fewer boxes do not, by themselves, make a better state.

