(In)Canon
Deterministic admissibility
(In)Canon structural audit

NHS England Risk Management Framework — Structural Audit Report

Version: 30 June 2025. This page records what the text makes explicitly available to a machine before any inference or professional reconstruction.

This page is a structural (In)Canon audit of the NHS England Risk Management Framework (Version 30 June 2025). It records what the text makes explicitly available to a machine before any inference or professional reconstruction.

  • What it measures: whether normative statements contain explicit Actor, explicit Action, and a binding Accountability marker that could be treated as a commitment. Time anchors are detected and reported when present.
  • What “Non-auditable” means here: the statement lacks at least one required explicit element (often Actor or Accountability), so a human would need to supply missing structure for the statement to be machine-actionable.
  • What it is not: this is not a risk assessment, governance judgement, legal/clinical interpretation, or a quality score. It makes no recommendations and does not claim the policy is “good” or “bad”.
  • Why this matters for AI use: when structure is missing, AI systems can still generate fluent outputs, but they do so by filling gaps implicitly. This report shows where that gap-filling pressure occurs.
Payoff up front

This audit treats “absence” as data: when Actor, Action, or an accountability marker are not explicitly stated, the statement is not structurally self-contained for machine execution.

Total candidate normative statements

84

Auditable

38

Non-auditable

46

Time anchor explicitly present

21

Missing: 63
Rule-set and scope
Rule-set (what “auditable” means in this demo)

A statement is treated as auditable if it contains:

  • an explicit Actor, and
  • an explicit Action, and
  • a binding commitment marker that a machine could act on without human reconstruction (modalised obligation such as will / must / should / required, or explicit responsibility/approval language).

Time is recorded when present but is not required for pass/fail in this demo.

Non-auditable statements
How to read this table

“Non-auditable” means at least one required explicit element is not stated (most often Actor and/or Accountability). This is a structural status only.

NON-AUDITABLE
Page3 Sentence #3 Time
Missing Actor, Accountability

risk management will become an integral part of NHSE’s culture

NON-AUDITABLE
Page3 Sentence #4 Time
Missing Actor, Accountability

risk management will be integrated into activities across the organisation, including policy making, planning and decision making

NON-AUDITABLE
Page4 Sentence #2 Time
Missing Actor, Accountability

Management of issues will either be through programme / project management reporting, or through existing local management reporting.

NON-AUDITABLE
Page4 Sentence #3 Time
Missing Actor, Accountability

pre-identified risks that later become issues) will continue to be tracked via the risk reporting process to ensure adequate visibility and provide assurance that they are being controlled, however they may be managed separately.

NON-AUDITABLE
Page4 Sentence #4 Time
Missing Actor, Accountability

Issues that may impact existing risks should be considered when undertaking risk review exercises.

NON-AUDITABLE
Page4 Sentence #5 Time
Missing Actor, Accountability

2.1 Roles & responsibilities Each area of the organisation must undertake an ongoing robust assessment of risks and escalate risks through NHSE’s governance and escalation route, as set out in the NHSE Risk management process and procedures manual.

NON-AUDITABLE
Page5 Sentence #2 Time
Missing Actor, Accountability

It is key to achieving effective risk management and should be considered before risks are addressed.

NON-AUDITABLE
Page5 Sentence #4 Time
Missing Actor, Accountability

when considering threats, risk appetite sets the level of exposure which is considered acceptable should the risk be realised.

NON-AUDITABLE
Page5 Sentence #5 Time
Missing Actor, Accountability

It balances the cost (financial or otherwise) of constraining the risk with the cost of the exposure should it become a reality.

NON-AUDITABLE
Page5 Sentence #8 Time
Missing Actor, Accountability

All risks should be analysed with risk appetite in mind.

NON-AUDITABLE
Page5 Sentence #9 Timeby the appropriate governance forum
Missing Actor, Accountability

Where target scores remain outside the agreed appetite level, additional mitigations will need to be proposed, or a decision taken by the appropriate governance forum to tolerate a position of operating outside of appetite.

NON-AUDITABLE
Page6 Sentence #2 Time
Missing Actor, Accountability

including portfolios Level 3 Sub teams, Risks that are related to the delivery of sub-team including operations and objectives and have the potential to programmes threaten delivery of a broader objective should they not be adequately mitigated.

NON-AUDITABLE
Page6 Sentence #3 Time
Missing Actor, Accountability

Level 4 Individual teams, Risks that are related to the delivery of individual pieces of work and team operations and objectives and have the projects potential to threaten delivery of a sub-team objective should they not be adequately mitigated.

NON-AUDITABLE
Page7 Sentence #3 Time
Missing Actor, Accountability

For each risk on our risk registers, we should determine:

NON-AUDITABLE
Page7 Sentence #4 Time
Missing Actor, Accountability

All scores must be recorded in the relevant risk register in CoreStream.

NON-AUDITABLE
Page7 Sentence #6 Time
Missing Actor, Accountability

The level and type of treatment will vary depending on the level of residual risk that has been determined and the tolerance for managing risk to within its risk appetite.

NON-AUDITABLE
Page7 Sentence #7 Time
Missing Actor, Accountability

To change the risk’s likelihood and/or consequences, existing controls will need to be enhanced, or new controls implemented.

NON-AUDITABLE
Page7 Sentence #8 Time
Missing Actor, Accountability

A risk action plan (also referred to as a risk mitigation plan) should be put in place to address any gap in controls.

NON-AUDITABLE
Page7 Sentence #9 Time
Missing Actor, Accountability

If a risk is being accepted it still needs to be regularly monitored, as circumstances may change which could result in different treatment in the future.

NON-AUDITABLE
Page7 Sentence #10 Time
Missing Actor, Accountability

4.2.3 Review Risk should be considered regularly as part of the normal flow of management information about the organisation’s activities and in significant decisions on strategy, business planning, 1 Risk sharing is the practice of distributing risks amongst several organisations, departments or teams to provide alternative approaches to mitigating the risk.

NON-AUDITABLE
Page8 Sentence #2 Time
Missing Actor, Accountability

Evidence of such reviews may be required to assess compliance with the framework across the organisation.

NON-AUDITABLE
Page8 Sentence #5 Timeno less than quarterly
Missing Actor, Accountability

Risk registers should be kept up to date and reviewed no less than quarterly.

NON-AUDITABLE
Page8 Sentence #6 Time
Missing Actor, Accountability

New risks should be added as they are discovered.

NON-AUDITABLE
Page9 Sentence #2 Time
Missing Actor, Accountability

Each directorate and region should consider and document how the second line will be enacted within their area of the organisation.

NON-AUDITABLE
Page9 Sentence #5 Time
Missing Actor, Accountability

In addition to reviewing the Strategic and Operational risk registers at each meeting, they will get risk based deep dives of those risks where:

NON-AUDITABLE
Page10 Sentence #3 Time
Missing Actor

Each team is responsible for defining their internal risk review and reporting arrangements, which should be proportionate to its local needs.

NON-AUDITABLE
Page10 Sentence #4 Timeno less than quarterly
Missing Actor, Accountability

Individual risks and risk registers should be reviewed no less than quarterly.

NON-AUDITABLE
Page10 Sentence #7 Time
Missing Actor, Accountability

Where cross-organisation risks do not fit within the remit of the ECG, they will be raised to the relevant governance forum at the time.

NON-AUDITABLE
Page11 Sentence #1 Time
Missing Actor, Accountability

The above is only a guide, and in general risks should be considered for escalation where:

NON-AUDITABLE
Page11 Sentence #2 Time
Missing Actor, Accountability

Where a team believes a risk may require escalation, the process for doing this will be as follows:

NON-AUDITABLE
Page11 Sentence #3 Timeby the risk register owner
Missing Actor

from level 4 to level 3) must be endorsed by the risk register owner where the risk currently sits, as well as the receiving risk register owner and / or the forum at that level.

NON-AUDITABLE
Page11 Sentence #4 Timeby the national director leading
Missing Actor

Escalation from level 1 risk register onto the SRR or ORR: escalation must be endorsed by the national director leading on the area that the risk is being escalated from.

NON-AUDITABLE
Page11 Sentence #5 Timeby ERG
Missing Actor

Escalation of the risk must be approved by ERG.

NON-AUDITABLE
Page11 Sentence #6 Timeby the national director leading
Missing Actor

Escalation of a cross-organisation risk either newly identified or from a level 1 risk register onto the ORR: escalation must be endorsed by the national director leading on the area that the risk is being escalated from.

NON-AUDITABLE
Page11 Sentence #8 Time
Missing Actor, Accountability

Continued monitoring and reporting of the risk will sit with the ERG, other than where deep dives may be required.

NON-AUDITABLE
Page12 Sentence #2 Timequarterly
Missing Actor, Accountability

Otherwise the risk will form part of established quarterly reporting.

NON-AUDITABLE
Page13 Sentence #2 Timeby the above activities and
Missing Actor, Accountability

Compliance reporting will be informed by the above activities and reported to ERG at least twice a year, and annually to ARAC.

NON-AUDITABLE
Page14 Sentence #1 Time
Missing Actor, Accountability

When there are gaps in controls, a mitigation plan should be agreed.

NON-AUDITABLE
Page14 Sentence #2 Timeby their nature will include
Missing Actor, Accountability

Note: These risks will be specific to the corporate team/region in question and by their nature will include operational or project delivery risks over which the corporate team/region has full or partial control.

NON-AUDITABLE
Page15 Sentence #1 Time
Missing Actor, Accountability

It risk criteria) is used to determine whether a specified level of risk is acceptable or tolerable; and should reflect organisational values, policies, and objectives, be based on external and internal context, should consider the views of stakeholders, and should be derived from standards, laws, policies, and other requirements such as delegations of authority and operating limits/thresholds.

NON-AUDITABLE
Page16 Sentence #1 Time
Missing Action

Annex 2: Roles & responsibilities Role Responsibility All staff Responsible for:

NON-AUDITABLE
Page16 Sentence #4 Time
Missing Actor, Action

Risk Responsible for: Register • participating (as appropriate) in the identification, assessment, Owners, e.g.

NON-AUDITABLE
Page17 Sentence #2 Timeby the Board
Missing Action

Executive Responsible for: Risk Group • oversight of NHSE’s risk exposure in the context of the risk appetite that has been agreed by the Board

NON-AUDITABLE
Page18 Sentence #2 Timeby ensuring
Missing Actor

They must ensure that risk management is integrated into all activities, and should demonstrate leadership and commitment by ensuring:

NON-AUDITABLE
Page18 Sentence #4 Time
Missing Action

Risk The Risk Management team is the corporate team directly accountable Management to the Chief Risk Officer.

NON-AUDITABLE
Page18 Sentence #5 Timeevery two years
Missing Actor

The team is responsible for: Team • maintaining a suitable risk management framework and any associated procedures and updating them every two years or following significant change

Auditable statements
How to read this table

“Auditable” means Actor + Action + an accountability marker are explicitly present in the statement under the demo rule-set. This is a structural classification only.

AUDITABLE
Page3 Sentence #1 Time
Actor
NHSE
Accountability
present
Action
will ensure that decisions made on behalf of the organisation are taken with
Time

NHSE will ensure that decisions made on behalf of the organisation are taken with consideration to the effective management of risks.

AUDITABLE
Page3 Sentence #2 Time
Actor
Board
Accountability
present
Action
will have a means of receiving assurance that strategic and operational risks are
Time

the Board will have a means of receiving assurance that strategic and operational risks are being identified and managed

AUDITABLE
Page4 Sentence #1 Time
Actor
CSUs
Accountability
present
Action
will have their own local arrangements for recording and governance.
Time

The broad principles of the framework also apply to Commissioning Support Units (CSUs), although they will have their own local arrangements for recording and governance.

AUDITABLE
Page5 Sentence #1 Time
Actor
Risk Appetite The Board
Accountability
present
Action
will guide staff in their actions and ability to accept and manage risks.
Time

Risk Appetite The Board is responsible for risk appetite and has developed a Risk Appetite Statement which forms part of NHSE’s overall risk management strategy and will guide staff in their actions and ability to accept and manage risks.

AUDITABLE
Page5 Sentence #3 Time
Actor
The Board
Accountability
present
Action
will be a range of appetites for different risks and these appetites may
Time

There will be a range of appetites for different risks and these appetites may vary over time; in particular the Board will consider varying the amount of risk which it is prepared to take as circumstances change i.e., during periods of increased uncertainty or adverse changes in the operating environment.

AUDITABLE
Page5 Sentence #6 Time
Actor
Staff
Accountability
present
Action
should be taken to mitigate a threat, the NHSE Board has adopted a
Time

To support consistency and enable staff to take well calculated risks to improve delivery when opportunities arise, and also to identify when a more cautious approach should be taken to mitigate a threat, the NHSE Board has adopted a qualitative approach to risk appetite and has structured risk appetite around several principal risk types.

AUDITABLE
Page5 Sentence #7 Time
Actor
Risk Owner
Accountability
present
Action
should determine which risk appetite category their risks best align to.
Time

Each Risk Owner should determine which risk appetite category their risks best align to.

AUDITABLE
Page6 Sentence #1 Time
Actor
Directorates
Accountability
present
Action
should they not be adequately mitigated.
Time

Level 2 Sub-directorates / Risks that are related to the delivery of team teams immediately objectives and have the potential to threaten below directorates delivery of a directorate or regional objective and regions, should they not be adequately mitigated.

AUDITABLE
Page7 Sentence #1 Timeby the subject matter experts
Actor
NHSE
Accountability
present
Action
should be applied by the subject matter experts articulating and managing each risk,
Time
by the subject matter experts

Therefore, the risk scoring guidance set out within the NHSE Risk management process and procedures manual should be applied by the subject matter experts articulating and managing each risk, with risk score calibration then taking place within the risk management governance framework to ensure consistency.

AUDITABLE
Page7 Sentence #2 Time
Actor
NHSE
Accountability
present
Action
should be scored at the point they are identified.
Time

NHSE’s risks should be scored at the point they are identified.

AUDITABLE
Page7 Sentence #5 Time
Actor
Risk Owner
Accountability
present
Action
will be treated.
Time

4.2.2 Treatment Once a risk has been identified, the risk owner needs to consider how it will be treated.

AUDITABLE
Page8 Sentence #1 Timequarterly
Actor
NHSE
Accountability
present
Action
will be reviewed quarterly by risk owners and considered collectively by the appropriate
Time
quarterly

It is NHSE’s minimum expectation that risks will be reviewed quarterly by risk owners and considered collectively by the appropriate management forum on the same timescale.

AUDITABLE
Page8 Sentence #3 Time
Actor
NHSE
Accountability
present
Action
must be recorded on the platform and cannot be kept locally; this includes
Time

4.3 Recording risks CoreStream is the system that we use to manage all risks at NHSE, therefore all risks must be recorded on the platform and cannot be kept locally; this includes programme risks.

AUDITABLE
Page8 Sentence #4 Time
Actor
NHSE
Accountability
present
Action
should be escalated through our governance structure.
Time

NHSE’s risk registers allow regions and directorates to capture all the information needed to manage risk appropriately and determine whether any risks should be escalated through our governance structure.

AUDITABLE
Page9 Sentence #1 Time
Actor
The Risk Management Team
Accountability
present
Action
responsible for co-ordinating, facilitating and overseeing the organisation’s effectiveness and integrity.
Time

The corporate risk management team and other internal oversight teams such as governance, legal, IT, performance/business planning, finance and HR (among others) form the second line of defence and are responsible for co-ordinating, facilitating and overseeing the organisation’s effectiveness and integrity.

AUDITABLE
Page9 Sentence #3 Time
Actor
The Executive Risk Group
Accountability
present
Action
will be responsible for overall risk oversight and approval, while Board committees will
Time

4.4.2 Risk governance for the Strategic Risk Register (SRR) & Operational Risk Register (ORR) The Executive Risk Group will be