Post Office Ltd is a public corporation. This means that it has greater autonomy from government than most public bodies, and its board is responsible for its operations. But the government is its sole shareholder and agrees its business plan.

The relationships between ministers, civil servants, and a public corporation’s board and senior team always make accountability complex. But there are additional complexities in the Post Office case, due to changes in regulatory structures, Fujitsu’s role in delivering Horizon, and the privatisation of Royal Mail – with the Shareholder Executive (now UK Government Investments) also playing a role in overseeing the privatisation as well as the Post Office’s regulatory and policy framework. ¹⁶ www.nao.org.uk/wp-content/uploads/2007/02/0607255.pdf, p. 5

The Royal Mail privatisation process would have been at least distracting for senior leaders, even if it did not actively incentivise the avoidance of bad news. The merger of Postcomm – which oversaw the postal market until 2011 – with Ofcom could also have meant less focus from the regulator on postal issues than other parties assumed was the case. Post Office Ltd had its own prosecutorial powers, so assumptions as to how the justice system would have held it to account could also have been misplaced.

These complexities mean that if any accountable person wanted to believe that someone else should have gripped the problem instead of them, plenty of such candidates were available. It is not yet clear which of the successive chairs, chief executives, board members, shareholder directors, regulators, departmental sponsors or ministers should carry the can, if any – but, collectively, there was a lack of clear accountability from which the government must learn. This is not just a question of who should have spotted and acknowledged the problem, but who should have driven its resolution over time.