Officers, Police, and the Quiet Machinery of Competence

Licensing only works because of people who do the unglamorous work well.

I want to pay tribute to Robert Breese, Aggie Minas, Andre Hewitt, and colleagues across licensing, environmental health, fire, and the City of London Police.

The City Police are unique — not only because they guard gold and investigate fraud, but because they understand premises, context, and proportion.

That shared professional culture is rare. And it shows.

 

The Croquembouche of Licensing Policy – Reforms to  the regime under the Licensing Act 2003

Licensing law today resembles a croquembouche , that elegant French tower of profiteroles.

At the base, the Licensing Act 2003.
Above it, section 182 guidance.
Then local licensing policy statements.

A pyramid, certainly,  but a manageable one.

What the City has done, quietly and sensibly, is encourage resolution before application.

Talk early.
Solve problems early.
Avoid unnecessary conflict.

So many City applications are resolved without ever being submitted — a level of efficiency which, in most other boroughs, would be treated with immediate suspicion.

 

A Short Detour into Licensing History

Whenever we talk about reform, it is worth remembering where licensing law actually began.

One of my favourite pieces of legislation in this field is the Disorderly Houses Act of 1751, an Act which, astonishingly, survived until 2008.

I won’t read it all, but I do want to read you just the opening lines, because they tell you everything you need to know about how Parliament once viewed entertainment.

“Whereas the multitude of places of entertainment for the lower sort of people is another great cause of thefts and robberies…”

“…as they are thereby tempted to spend their small substance in riotous pleasures…”

“…and in consequence are put on unlawful methods of supplying their wants…”

“…and of renewing their pleasures.”

 

That, ladies and gentlemen, was Parliament’s considered view of dancing.

The concern was not noise.
Not nuisance.
Not cumulative impact.

The concern was that music and dancing might lead directly to idleness, theft, robbery, and the general moral collapse of the kingdom.

And the solution was admirably straightforward.

Four justices.
In open court.
Licence read aloud.
And if you didn’t have one, a constable could enter, seize everyone present, and deal with them according to law.

All very proportionate.

Parliament, at least, was honest.

They didn’t talk about streamlining, or simplification, or improving the customer journey.

They simply said: we don’t trust people to dance.

 

Why Government Feels the Need to “Help”

Before I turn to licensing reform itself, it is only fair to acknowledge why Government is reaching for it.

Ministers want to be seen to offer a helping hand, because at the same time, the hospitality sector is under pressures the likes of which it has rarely seen.

Put bluntly, the Government taketh away with one hand, and giveth with the other and the giving hand is sometimes the smaller of the two.

The industry’s trade body, UKHospitality, has estimated that a cluster of measures landing in the same period amounts to over £3 billion a year in additional costs for the sector.

That includes around £1 billion from changes to employer National Insurance alone, translating into around £2,500 extra per full-time employee, for pubs and restaurants already operating on wafer-thin margins.

Then there is business rates.

With pandemic relief unwound and revaluation effects kicking in, some smaller pubs have seen their rates bills rise by several hundred per cent, and UKHospitality has warned that the average pub could be paying tens of thousands of pounds more over the next few years than it did during the relief period.

Closures are the quiet backdrop to all of this.

Industry figures suggest pubs are still closing at a rate of around eight a week across England and Wales, not in dramatic collapses, but in a steady drip that changes high streets and communities almost unnoticed.

Layer onto that the Employment Rights Bill.

Much of it is well-intentioned. But it lands hardest in sectors like hospitality that rely on flexibility, late hours, and young people taking their very first job.

Employers are being asked to manage new duties around workplace conduct, sometimes caricatured in the press as a “banter ban”, in environments that are social, informal, and fast-moving by nature.

So when Ministers speak about simplifying and streamlining licensing, part of what they mean is this:

we have made trading harder in many other ways, and we now want to be seen to make something easier.

Which brings me neatly to reform, and to Ronald Reagan’s nine words.

 

Licensing Reform and the Risk of Bureaucracy

There is a famous warning from Ronald Reagan, who once said that the nine most terrifying words in the English language are:
“I’m from the government, and I’m here to help.”

I wouldn’t go quite that far,  but what we are now seeing is a nascent piling-up of bureaucracy from the centre, with a real risk that local judgment begins to be displaced.

The Government’s review of licensing law and procedure, concluding at the end of 2025, starts from understandable concerns: inconsistency, delay, complexity, and unpredictability.

Out of it have come familiar themes:
greater front-loading,
earlier engagement,
clearer frameworks,
and a drive for consistency.

All of that is defensible.

But the pyramid is becoming steeper.

The Licensing Act still anchors the system.
But now we see a proposed National Licensing Policy Framework alongside section 182 guidance.
In London, the Mayor’s licensing strategy sits above local policy statements.
And above all of that, a call-in power coming down the track, removing strategic applications from local decision-makers altogether.

Taken together, the risk is not reform.

It is hierarchy.

That discretion gives way to templates.
That judgment gives way to compliance.

And if we add many more layers of policy, I can only assume the croquembouche will require structural engineering consent!! ……