Welcome to our ‘living’ interactive guide to the new Labour government’s first 100 days in office. The graphic and subsequent pages chart a course to what is likely to be the flagship event of the new government just beyond the end of the period: its first full budget with full OBR costings. Before that, actual parliamentary time to enact new legislation will be short given the summer recess starting around the end of July/ beginning of August and then the party conference season in September.
But along the way it will begin to lay the groundwork for its ambitious legislative programme, key elements of which we have summarised under the following themes:
Latest updates (1 August):
- The first trimester – a brief review
- 31 July: Deputy Prime Minister updates proposals for planning reform
- 29 July: Rachel Reeves’ “black holes” and other Treasury notices
- 18 July: European Political Community Meeting
- 17 July: The King’s Speech
- 9-11 July: NATO Summit
- Tax, fiscal and monetary policy
- Financial Services
- UK-EU Relations
- Employment
- ESG and sustainable finance
- Artificial Intelligence
- Healthcare and Life Sciences
- Infrastructure
- Real Estate
This is not intended to be an exhaustive list of policies and clearly is subject to change. But it does provide a guide to what we understand to be the current direction of travel for the new government. It has been collated from a variety of sources including the analysis of many of our expert lawyers and our Client Insights Lead.
Please feel free to reach out to your usual contacts at Simmons & Simmons for their further guidance on key issues as they affect your business.
First 100 Days: the first trimester – a brief review
When is a black hole not a black hole? It’s a puzzle not for Stephen Hawking but for lesser mortals trying to anticipate the first budget from Rachel Reeves. The new chancellor chose the end of July, when summer holidays beckon in the northern hemisphere and financial markets languish in the doldrums, to announce the discovery of a claimed (and contested) £22bn-sized “black hole” in the public finances. It will require some ‘tough decisions’ if it is to be plugged at her October 30th budget.
It was by far the most dramatic development of the new Labour government’s first trimester of its First 100 Days in office. Elsewhere the set piece of the Kings Speech and other ministerial announcements have broadly followed the manifesto commitments made during the election including those to improve relations with our most important trading partners, notably Europe.
Financial markets remain broadly unmoved but there are just the faintest of nods of approval. But they and the rest of us will spend the next trimester trying to understand how Reeves might collapse the black hole; in the astronomical realm such an event tends to be a dramatic one.
Financial markets are not the only lens through which to assess the success or otherwise of a chancellor’s performance or indeed a whole new administration. But they are an important bell-weather given this government’s need to ‘crowd-in’ £billions from the private sector to do the heavy lifting on its ambitious investment programmes.
Their judgement so far, while muted, contains a few modest nods of approval: sterling has strengthened a little since the election, bond yields have continued to ease lower and the FTSE250 index of companies more exposed to the UK domestic economy has outperformed its bigger and more internationally focussed counterpart, the FTSE100 index. No signs yet of any fears that the new government is likely to cause inflation to spike or to scare overseas investors.
Using our freshly updated guide to the First 100 Days below (first published on July 5th – the day after the election) the following sections provide important progress-checks in the run up to the summer recess shortly upon us and help to anticipate the shape of the remainder of Labour’s First 100 Days and beyond.
31 July: Deputy Prime Minister updates proposals for planning reform
Planning reform was one of the key planks on which the Labour Manifesto built its proposals significantly to increase UK GDP growth. DPM Angela Rayner has made a series of announcements since taking office and most recently to outline the direction of travel – and some immediate actions.
Our 5 key takeaways are:
Ambitious Housing Targets
The government is updating the National Planning Policy Framework to bring back mandatory housing targets. The new targets aim to boost housebuilding in areas most in need, with the goal of building 1.5 million new homes over the next five years. Local authorities will be required to plan for the number of homes their communities need.
Prioritising Brownfield and 'Grey Belt' Development
If local authorities can't meet their housing targets, they will need to look to brownfield land and 'grey belt' land (areas within the green belt), prioritising sites near stations and existing settlements. Grey belt sites will only be built on if they meet the government's 'golden rules', including that half of the homes built must be affordable and the necessary infrastructure is in place.
Streamlining Infrastructure Delivery
The government will make it easier to build digital infrastructure, laboratories, and gigafactories for electric vehicle batteries. The National Planning Policy Framework will be updated to require local authorities to identify sites to meet the needs of a modern economy. The upcoming Planning and Infrastructure Bill will include measures to speed up the delivery of high-quality homes and infrastructure.
Establishing a New Towns Taskforce
Rayner is setting up a taskforce dedicated to identifying potential sites for a new generation of new towns within the next year. The taskforce, led by Sir Michael Lyons and Kate Barker, will aim for these new large-scale communities to have at least 10,000 new homes each, with a target of 40% affordable housing.
Removing 'Beauty' Requirements
In a controversial move, Rayner defended removing the requirement for new homes to meet a 'beauty' standard from the updated planning rules. This change is part of a larger overhaul of the planning system to boost housebuilding and economic growth, though critics argue it could lead to lower-quality developments.
See also comments from our Real Estate team here.
29 July: Rachel Reeves’ Spending Audit and other Treasury notices
Rachel Reeves’ Spending Audit
Ahead of the general election Reeves said she would “front-load the bad news” if Labour won and she has certainly done that, or gone towards it, in her so-called “spending audit”. But she had to tread carefully given the lack of OBR analysis to accompany her audit; many observers had, for that reason, anticipated that such an audit would be part of the full budget process, including OBR analysis and sign-off, now scheduled to be delivered on October 30th.
Here are our 5 key takeaways from her speech:
£22 Billion Spending Gap
Reeves revealed that a Treasury audit uncovered a £22 billion hole in the public finances inherited from the previous Conservative government. This included £6.4 billion on asylum and immigration, £1.7 billion in excess military assistance to Ukraine, and £1.6 billion to prop up the railways, among other unfunded commitments. The claim is hotly contested by former chancellor Jeremy Hunt
Public Sector Pay Settlements
Reeves announced that the government would accept the recommendations from pay review bodies for various public sector employees, typically suggesting a raise of around 5%, above inflation. Notably, a deal was reached with junior doctors, providing a 22.3% pay increase over two years. These pay settlements, estimated to cost £9.4 billion, are a likely significant contributor to the spending gap.
Immediate Spending Cuts
To address the overspend, Reeves announced £5.5 billion in savings this year and £8.1 billion next year. Measures include seeking over £3bn of departmental savings this year, ending the Rwanda migration scheme, scrapping the Advanced British Standard and certain road/rail projects, reviewing the New Hospital Programme, and restricting Winter Fuel Payments to only the poorest pensioners.
Upcoming Budget and Spending Review
Reeves confirmed she will hold a Budget on October 30th alongside an OBR forecast. The Budget will involve "difficult decisions" on spending, welfare and tax to meet fiscal rules (see below). She also launched a multi-year Spending Review to set departmental budgets for at least 3 years and provide long-term certainty.
Adhering to Fiscal Principles
Reeves pledged to treat taxpayers' money with respect, honour the manifesto commitment to not raise income tax/NI/VAT rates, and meet fiscal rules to balance the current budget and get debt falling as a share of GDP. However, she warned of challenging decisions and trade-offs ahead on tax and spending, hinting at potential tax increases on wealth in the upcoming Budget (see below).
The claim of the £22bn “black hole” has been hotly contested by the former chancellor, Jeremy Hunt, who has written to the Cabinet Secretary to seek clarification. He has also pointed to the fact that a significant portion of the black hole is the direct consequence of the decisions also announced to fully fund the public sector pay review recommendations and to settle the junior doctors’ long-running industrial action
Nonetheless, the head of the Office of Budget Responsibility appears to have given the claim some credence at least to the extent that he has ordered its own review into the estimates it was given on which to base its analysis of the March budget delivered by the then chancellor, Jeremy Hunt.
So, it promises to be a hot summer in some quarters as the full details of the financial “black hole” are determined - a notoriously tricky process based on the astronomical variety!
But almost whatever the outcome of those reviews, the cuts announced by Reeves so far would, if fully realised, reduce the black-hole ‘overspend’ by some £13.6bn over the course of this year and next. The remainder of the £22bn (around £8.3bn) will only add to speculation that the budget on October 30th will see some combination of:
further taxes beyond those identified in the manifesto (see the Tax/Fiscal section below) with changes to some CGT rates and some IHT exemptions among the most commonly mentioned by commentators. The Resolution Foundation in a recent report estimated that ending or limiting some IHT reliefs could raise an additional £2bn a year in tax revenues and that raising CGT rates on share sales (so as to be in line with income tax rates) could raise up to £7.5bn a year. Taken together they would close a large proportion of Reeves’ claimed black hole. Note that Torsten Bell, the former CEO of the Resolution Foundation, is now a Labour MP.
modification to the fiscal rule requiring debt-to-GDP to be falling in the final year of the parliament, which would allow additional borrowing.
So far the financial markets seem unmoved by such speculation.
Other Treasury Notices
In addition to the set-piece speech to Parliament, HM Treasury released the following policy papers and consultations on the same day
Changes to the taxation of non-UK domiciled individuals
From 6 April 2025, the government will remove the concept of domicile status from the tax system and implement a new residence-based regime which is “internationally competitive and focused on attracting the best talent and investment to the UK”. Follow the link above for further details
Applying VAT to Private School Fees and Removing the Business Rates Charitable Rates Relief for Private Schools Technical Note
The government has published a technical note outlining the design, scope, and expected impact of applying 20% VAT to private school fees across the UK and removing the business rates charitable rates relief for private schools in England. The note invites comments on some technical aspects of the policies, specifically around legislative definitions used in the VAT legislation. Draft legislation on the VAT policy change has also been published alongside this technical note. It is intended that the changes to VAT will take effect from 1 January 2025 and will apply to any forward payments made after 29 July, 2024
The Tax Treatment of Carried Interest – Call for Evidence
This call for evidence confirms the government’s intention to take action against what it describes as the carried interest “loophole” and forms the basis for detailed engagement with expert stakeholders. It also sets out a series of areas where HMT would particularly value input from stakeholders.
Changes to the Energy (Oil and Gas) Profits Levy
This document sets out the changes announced to the Energy (Oil and Gas) Profits Levy (EPL) in line with the government’s manifesto commitments.
And a few days before Reeves’ speech (25 July):
TCFD-aligned disclosure Exposure Draft for Phase 3
Public consultation on HM Treasury's Phase 3 Exposure Draft for Task Force on Climate-related Financial Disclosure (TCFD)-aligned disclosure in annual reports.
18 July: European Political Community Meeting
As we suggested in our original 5 July publication of The First 100 Days, the EPC, originally conceived to coordinate European aid to Ukraine, could also become a forum for wider cooperation between the UK and Europe more generally – not just the EU. Sir Keir Starmer appears to have capitalised on that opportunity at the meeting hosted by the UK. Here are five key takeaways which point towards that closer cooperation:
Resetting UK-EU relations
The summit provided Starmer an opportunity to showcase his government's commitment to resetting Britain's relationship with Europe post-Brexit. He emphasised a pragmatic approach focused on cooperation and finding collaborative solutions, which was reportedly well-received by European leaders like Macron, Sánchez, and Scholz.
Demonstrating leadership on Ukraine
Starmer reaffirmed the UK's support for Ukraine in discussions with the 46 European leaders present, including President Zelenskyy who addressed the summit. He pledged ongoing assistance for Ukraine's energy needs and efforts to crack down on ships helping Russia evade sanctions.
New approach to illegal migration
Starmer announced a "reset" in the UK's approach to tackling illegal migration, with plans to work closely with European partners to disrupt smuggling networks. This includes increasing the UK's presence at Europol, new cooperation arrangements with countries like Slovenia and Slovakia, intelligence sharing via the new UK Border Security Command, and £84 million in funding for projects in Africa and the Middle East to address migration at its source.
Strengthening European security cooperation
Discussions at the summit focused on deepening UK-EU cooperation on defence, security, protecting democracies from Russian interference, and supporting countries facing direct threats. Starmer aims to negotiate a new security agreement with the EU covering areas like human trafficking, external interference, border security, and more.
Successful bilateral engagements
Starmer used the summit to hold productive bilateral meetings with key European leaders. Notable interactions included Irish Taoiseach Simon Harris, with plans for Starmer to visit Dublin soon, as well as French President Emmanuel Macron and Polish Prime Minister Donald Tusk.
17 July: The King’s Speech
The legislative road ahead looks remarkably busy after the Kings Speech outlined 40+ new bills to be introduced in this parliament – the highest number since 2005.
Our five key takeaways are:
Focus on economic growth and stability
Several bills were announced aimed at boosting economic growth, including establishing a National Wealth Fund to attract private investment, reforming pensions, streamlining planning and infrastructure, and strengthening workers' rights. A "fiscal lock" bill will require independent assessments of major tax and spending changes.
Renationalising rail and improving transport
The speech outlined plans to bring railways back into public ownership through the Passenger Railway Services (Public Ownership) Bill. A Railways Bill will establish Great British Railways. The Better Buses Bill will allow more local control over bus services.
Expanding devolution and local powers
An English Devolution Bill will create a standardised framework to accelerate the transfer of powers to metro mayors and combined authorities in areas like housing, transport and planning. A new Council of Nations and Regions was also proposed.
Establishing GB Energy and boosting renewables
Legislation will set up GB Energy, a new state-owned company headquartered in Scotland, to invest in and manage renewable energy projects like offshore wind and clean hydrogen. This aims to accelerate the UK's clean energy transition.
Social reforms in housing, health and education
Key social policy bills include strengthening renters' rights and ending "no-fault" evictions, modernizing the Mental Health Act, gradually raising the legal age to buy cigarettes, and forcing councils to register homeschooled children. Reforms to the House of Lords were also announced, including phasing out hereditary peers.
9-11 July: NATO Summit
The summit was something of a diplomatic “gift” for a Prime Minister only 4 days into his tenure to be able to establish himself on the global stage.
Here are our 5 key takeaways:
Demonstrating unwavering commitment to NATO
In his first international summit as Prime Minister, Starmer conveyed a clear message of the UK's enduring and steadfast commitment to the NATO alliance, collective security, and shared values. He emphasised Britain's instrumental role in NATO's creation 75 years ago and pledged to carry that legacy forward.
Strengthening support for Ukraine
Starmer reaffirmed the UK's robust support for Ukraine, announcing a substantial £3 billion military aid package through 2030-31 and beyond if needed. He urged NATO to send a united message to President Putin and stressed the importance of defending shared values and security interests.
Resetting UK-US relations
The summit provided an opportunity for Starmer to reset the UK's relationship with the US. His warm reception by President Biden in the Oval Office was intended to signal the strength of the US-UK "special relationship".
Engaging with global leaders
Starmer met with all 31 NATO leaders, underscoring his commitment to forging relationships and working collaboratively with allies, even those with differing political views.
Boosting UK defence spending
Starmer called on NATO allies to increase their defence spending given the various geopolitical security threats. He pledged to set out a clear path for the UK to spend 2.5% of GDP on defence and announced plans for a Strategic Defence Review to strengthen Britain's armed forces and protect national security.
Archive
On 5 July we published our original set of milestones for Labour's first 100 days in power. Click on the tabs below to see what we said at the time were the key actions for the new government.
5 July: King Charles III ‘appoints’ his new Prime Minister
Labour leader Sir Keir Starmer goes to Buckingham Palace to be appointed as the King’s Prime Minister. The 100 Days clock started ticking.
9 July: Parliament meets to elect the Speaker
No business is conducted in the House ahead of the King’s Speech except to elect the Speaker of the Commons and for all sitting MPs and Lords to swear allegiance to the sovereign.
9 – 11 July: NATO Summit
Meeting to be held in Washington. Likely the first major foreign policy test of the new Prime Minister and his Foreign Secretary, although both may be late arrivals given events in the House of Commons on 9 July (see above). Agenda items will include “NATO’s military presence in the east of the Alliance” which extends from the Baltic Sea in the North to the Black Sea in the South - the fault line defining the theatre of conflict around the invasion of Ukraine. The meeting will mark the 75th anniversary of the founding of NATO and will be the last for current Secretary General Stoltenberg before former Dutch PM Mark Rutte takes up the role from 1 October. The meeting is set against the background of conjecture as to the outcome of the US Presidential election in November 2024 and the rightward drift in the composition of the European Parliament. Both have possible implications for NATO strategy and funding.
17 July: State opening of Parliament and the King’s Speech
The State Opening marks the formal start of the parliamentary year. The King's Speech sets out the government’s proposed policies and legislation for the coming session. It is followed typically by 2 or 3 days of debate in the House to approve the King's Speech. Although rare, the monarch’s speech can be defeated and – if it is – would normally be taken as a resignation matter for the government.
18 July: UK to host the European Political Community Meeting
This will be the fourth meeting of the EPC, formed in response to Russia’s invasion of Ukraine. It is a supra-national body whose 50 or so members come from Europe - within and beyond the European Union.
Of significance to the extent of its convening powers – and potentially to the new Labour government - President Macron of France in an address to the European Parliament in 2022 described the EPC as a “new European organisation” that would allow “democratic European nations that subscribe to our shared core values [to] find a new space [for] political and security cooperation, cooperation in the energy sector, in transport, investments, infrastructures, the free movement of persons and in particular of our youth”
That latter element (freedom of movement for youth) may have been anathema for the UK’s previous administration but for the new Labour government it could allow the fulfilment of Labour’s ambitions for a closer working relationship with the EU without rejoining the Single Market or Customs Union.
Rest of July/early August: begin a new legislative programme
Tax/Fiscal
The following measures have been extracted from the Labour manifesto and subsequent commentary. Whilst many of these items will be matters for a formal Budget (see later) followed by consultation on draft legislation that is to be enacted in a Finance Act that will mostly likely become law in Q1 2025, the expectation is that some of the detail that has to date been outstanding may emerge prior to the Budget:
- abolish non-dom status once and for all, replacing it with a modern scheme for people genuinely in the country for a short period, including closing the “loopholes” in the Conservative Spring Budget 2024 plans to remove non-dom status such as the treatment of offshore trusts for inheritance tax purposes
- close the “carried interest” loophole by taxing “carried interest” as income (this doesn’t necessarily specify how such a measure would operate, though it is forecast to raise £565m in 2028/29)
- close the loopholes in the windfall tax on oil and gas companies - Labour will extend the sunset clause in the Energy Profits Levy until the end of the next parliament and increase the rate of the levy by 3%, as well as removing the generous investment allowances
- end the VAT exemption and business rates relief for private schools
- increase the rate of the stamp duty surcharge paid by non-UK residents by 1%
- replace the business rates system, to raise the same revenue in a fairer way – this new system intends to level the playing field between the high street and online giants, better incentivise investment, tackle empty properties and support entrepreneurship
- Labour has stated that it will not increase the basic, higher, or additional rates of Income Tax; nor increase National Insurance or the rate of VAT, although the position in relation to capital gains tax remains to be confirmed
- Labour supports implementation of the OECD global minimum rate of corporate taxation and backs international efforts to make sure multinational tech companies pay their fair share of tax
- Labour will undertake a review of the pensions landscape to consider what further steps are needed to improve pension outcomes and increase investment in UK markets (it is not clear if this will involve consideration of the tax treatment of pensions and pension contributions, though it appears that Labour has dropped its plan to reintroduce the lifetime allowance)
- Labour plans to modernise HMRC and invest in efforts to tackle tax avoidance and tax evasion, with a view to further closing the tax gap
- Labour has committed to maintain a fiscal rule requiring the national debt-to-GDP ratio to be falling by the end of Year 5 of the parliament
Monetary Policy
- Reverse recent changes to downgrade climate change emphasis in the Bank of England's remit
- Potentially change the Bank of England's mandate to include a focus on productivity growth
Financial Services
- champion UK FS sector as “one of Britain’s success stories”
- deliver “inclusive growth” with regional financial centres and “unlocking the full potential” of the mutuals sector
- enhance international competitiveness of the UK FS sector including through “innovation-centred” regulation/ supervision and streamlined regulatory rulebook in line with Consumer Duty
- reinforce consumer protection and financial inclusion including with longer-term fixed rate mortgages, a national financial inclusion strategy and regulating the Buy Now Pay later sector
- lead the world in sustainable finance
- become global standard-setter for the use of AI on FS, deliver next phase of Open Banking and “embrace” securities tokenisation and a central bank digital currency
- British Business Bank: Empowering the bank to invest more in growth capital for businesses.
- British 'Tibi' Scheme: Establishing a program to increase institutional investment in venture capital and small cap growth equity.
- Solvency UK Reforms: Aiming to increase investment in infrastructure and green industries through regulatory reforms
- reform (“unlock”) workplace pension schemes to increase investment in UK markets including to invest in long-term infrastructure projects; will require care in relation to retail exposure to illiquid assets
- Edinburgh Reforms: Labour has expressed intentions to accelerate reforms proposed under the Edinburgh reform package, which aims to enhance the competitiveness of the UK financial services sector. These reforms were previously criticized for slow progress, and Labour plans to expedite their implementation to better align with EU standards and practices. In general Labour wants to work towards "compatible regulatory approaches" where regulations deliver similar outcomes See also under UK-EU relations (below)
UK-EU Relations
The Labour manifesto has only a few references to Europe (14 mentions, mostly regarding Ukraine/NATO), but including its ambition to improve trade relations and to champion UK financial services.
Substantial changes are likely deferred until the scheduled 2026 review of the Trade and Cooperation Agreement. Labour appears to plan for incremental moves initially, potentially becoming bolder if re-elected in 2028/29, envisioning a 10-year investment plan over two terms.
All of which said regarding incrementalism, the areas where a Labour government might “ditch the fixation with divergence” (a quote from Rachel Reeves) and seek earlier, closer working with the EU include:
UK-EU: Financial services
- Aligning the UK's carbon pricing regime (emissions trading scheme and carbon border adjustment mechanism) more closely with the EU's. Labour is exploring how to realign the UK's carbon market and border tax for imports with the EU's system to prevent UK industries from being undercut.
- Pursuing mutual recognition of professional qualifications for the financial services sector; seeks further mutual recognition agreements beyond the current one with Switzerland
- Exploring a "sustainable solution for cross-border clearing" to maintain access for UK clearing houses to EU markets.
UK-EU : Ireland/Northern Ireland: Windsor Agreement
- Although no specific measures have been cited by Labour, the relationship between Ireland and Northern Ireland remains a touchstone for UK-EU relations and the incoming Labour administration will have to deal with issues arising from, in particular, Article 18 which provides for a mechanism of “democratic consent” through periodic votes by members of the Northern Ireland Assembly. Article 18 relates to customs and the movement of goods, VAT and excise.
- The first vote under the protocol is scheduled to take place before the end of 2024 came into force. An important test for the incoming Labour administration
- Beyond the Windsor Agreement and Article 18, Labour has committed to negotiating a "veterinary agreement" to prevent unnecessary border checks and help tackle food costs. This could also help smooth trade between Britain and Northern Ireland across the Irish Sea border.
UK-EU: Other/security/longer-term
- Increasing foreign policy and security cooperation with the EU, potentially through a new UK-EU security pact
- Scheduled review of the UK-EU Trade and Cooperation Agreement (TCA) in 2026. Seen as an opportunity for Labour to make more substantive changes. In part driven by acknowledgment that Brexit has negatively impacted UK productivity
- Increase productivity to counter Brexit-related losses Rachel Reeves has acknowledged the OBR estimate of a 4% reduction in productivity potential due to Brexit)
- May attempt to influence EU policy through supranational forums eg the European Political Community (see above)
- Could use the TCA or Financial Services MOU as channels for cooperation
Employment
Labour's employment and labour market plans focus on improving workers' rights, boosting employment, and enhancing skills and training. The party aims to create what they call a "decade of national renewal" with several key initiatives. Note again the reference to a 10-year plan reinforcing the idea that their strategy is predicated on winning the next election in 2028 or 2029 also.
New Deal for Working People
- Possible Employment Rights Bill could be introduced in the first 100 days
- ban exploitative zero hours contracts (with some exceptions)
- End fire and rehire practices (with some exceptions)
- introduce basic rights from day one to parental leave, sick pay, and protection from unfair dismissal.
- strengthen the collective voice of workers, including through their trade unions
- create a Single Enforcement Body to ensure employment rights are upheld
- make sure the minimum wage is a genuine living wage
- strengthen the right to flexible working
- enhance rights for workers in the gig economy
Commitments to D&I including
- Enact the socio-economic duty in the Equality Act 2010
- Reduce gender pay gap
- Introduce landmark Race Equality Act to extend the right to equal pay from sex to race and disability
- Reverse the decision to downgrade the monitoring of antisemitic and Islamophobic hate
Skills and Training
- Labour plans to reform the skills system to better meet the needs of workers and businesses:
- Introduce a new 'Skills England' body to coordinate skills policy
- Reform the Apprenticeship Levy into a 'Growth and Skills Levy'
- Ensure everyone can access training throughout their working lives
- Introduce a 'Young Persons Guarantee' of education, training, or employment opportunities
ESG and sustainable finance
Arguably the single biggest programme within the Labour manifesto including its ambition to achieve net zero in electricity generation by 2030 – the only programme with explicit commitment to increase borrowing as part of the funding proposal. The proposals cut across all sectors of the UK economy and include all three pillars of the ESG agenda.
Labour's Environmental and Social Commitments
- Ambitious goal of achieving zero carbon electricity by 2030
- Plans to introduce a new Race Equality Act to address racial inequalities and mandate disability and ethnicity pay reporting
- Commitment to make the minimum wage a genuine living wage, removing age-based discrimination
Green Prosperity Plan and Energy Policies/ Infrastructure
- Proposal to establish a National Wealth Fund to attract private investment
- Aim to crowd in £3 of private sector investment for each pound of public money spent
- Great British Energy: A new publicly-owned clean energy company to invest in renewable energy projects.
- Warm Homes Plan: A £6.6 billion investment over the next parliament to insulate 19 million homes, reducing energy bills and emissions.
- Plans to offer clean energy developers a "British jobs bonus" of up to £500 million per year from 2026
- Overhaul the Contracts for Difference system for clean energy investments
- Interest in harnessing untapped potential of tidal and wave technology
- Funded partly by a windfall tax on oil and gas companies (£1.2 billion annually) and partly through borrowing (£3.5 billion annually).
Regulatory Approach:
- Intention to make climate change a policy priority for the Bank of England
- Plans to update the Bank of England's collateral framework and supervisory measures with climate change in mind
- Commitment to advancing plans for a UK green taxonomy
- Pledge to make the UK the "green finance capital of the world"
- Require financial institutions and FTSE 100 companies to publish carbon footprints and adopt credible net-zero plans
Investment Focus:
- National Wealth Fund to target sectors such as ports, gigafactories, clean steel, carbon capture, and green hydrogen
- Recognition of UK's competitive edge in producing technologies needed for net-zero transition (e.g., electric trains, heat pumps, turbines)
Financial Sector Reforms:
- Plans to mandate UK regulated financial institutions to develop credible transition plans aligned with the 1.5°C Paris Agreement target
- Support for diversity and inclusion guidance for financial services led by the FCA and PRA
Just Transition and Job Creation:
- Emphasis on ensuring a just transition that doesn't leave anyone behind
- Proposal to establish Great British Energy, a publicly owned clean energy company, headquartered in Scotland
- Acknowledgment of potential job losses in the North Sea oil and gas industry and the need to address this challenge
Challenges and Constraints:
- Limited budget for implementing ambitious plans
- Need to "outsmart rather than outspend" to remain competitive
- Requirement to catalyse private finance and reduce bureaucracy
Comparison with International Efforts:
- Recognition that the proposed National Wealth Fund (£7.3 billion) is significantly smaller than the US Inflation Reduction Act ($350 billion)
- Need for the UK to offer a unique proposition to attract foreign investors
Potential Challenges:
- Balancing regulatory ambition with potential legal challenges, as seen with the SEC's climate disclosure rules in the US
- Addressing concerns from trade unions and regional parties (e.g., SNP) about job losses in traditional energy sectors
Non-Financial Levers:
- Focus on improving planning processes and grid connections for renewable energy projects
- Emphasis on reducing bureaucracy to facilitate green initiatives
Artificial Intelligence
The approach of the Labour government may not differ significantly from the current government's direction of travel. The post-Brexit focus on investment and innovation likely to continue and the current government had already hinted at binding regulation for the most capable AI models.
AI Sector Plan
- Developing a strategy to support the AI industry, though specific funding details are not provided.
- National Data Library: Creating a national resource to support cutting-edge research and data-driven public services.
- Regulatory Innovation Office: Establishing a new office to update regulation and speed up approval timelines for innovative products and services.
AI Regulation
- Commitment to introduce binding regulation on AI developers, replacing the current voluntary regime
- Focus on regulating "highly capable AI models"
- Potential establishment of a Regulatory Innovation Office
Key Considerations for AI Regulation:
- The specifics of regulation will be crucial (who is regulated, nature of regulation)
- Potential for more detailed regulation due to backbencher pressure
- Regulation may target both developers and users of AI models
- Enforcement will be a critical factor in the effectiveness of regulations
Challenges in AI Regulation:
- Rapidly evolving landscape makes it difficult to define "high impact" models
- Priorities may shift (e.g., from deepfakes to chemical weapons and cyberterrorism)
- Enforcement strength will determine the regulation's effectiveness
- UK's approach to AI regulation needs to consider its global context
Relationship with EU AI Act:
- UK unlikely to adopt the EU AI Act wholesale
- Potential for borrowing concepts, such as regulating general purpose AI models
- Recognition of merits in both EU and UK approaches to AI regulation
Healthcare and Life Sciences
- NHS Investment: Pledging to cut waiting lists and improve NHS performance, though specific funding details are not provided.
- Mental Health: Recruiting 8,500 new mental health staff at a cost of £410 million annually by 2028-29.
- Diagnostic Services: Doubling the number of NHS CT and MRI scanners, with an annual investment of £250 million by 2028-29.
- Dental Care: £125 million annually by 2028-29 for a dentistry package including 700,000 urgent appointments every year
- Aims to create 100,000 jobs by 2030
- Increase R&D in pharma by £10bn a year
- Planning reforms to increase laboratory space
- Establish Regulatory Innovation Office to hold regulators to account for delays in innovation
- Require UK Research and Innovation organisation to set 10-year budgets to provide greater certainty for longer-term investment
Infrastructure
The incoming Labour government has ambitious plans to revitalise the economy including through fostering significant improvements to productivity. The infrastructure sector will play a critical role in achieving those aims. The following is our summary of the key policy initiatives already announced in its manifesto or otherwise signalled by the Labour Party.
Great British Energy (GBE)
- New publicly owned clean energy company central to Labour's net zero plans
- To be established through a Great British Energy Bill
- Capitalized with £8.3 billion
- Three initial priorities:
- Co-investing in new technologies
- Scaling up and accelerating mature technologies
- Scaling up municipal and community energy
- Similarities with proposed National Wealth Fund (NWF) and existing UK Infrastructure Bank (UKIB)
National Wealth Fund (NWF)
- Proposed £7.3 billion fund
- Focus on ports, gigafactories, steel industry, carbon capture, and hydrogen
- Aims to help deliver £50-60 billion annual investment for UK's net zero requirements
UK Infrastructure Bank (UKIB)
- Already invests in economic infrastructure, networks, and technology to tackle climate change
Labour's Defence Policy
- Commitment to spending 2.5% of GDP on defence "as soon as possible"
- Emphasis on using defence industry to help drive economic growth
- Focus on European alliances and maintaining the nuclear deterrent
- Pledges to improve service accommodation
- Plans to establish a Military Strategic HQ in the first week of government
- Strategic Defence Review planned for the first year to assess armed forces' state and future needs of the military
Railway Reforms
- Taking the railway system into full nationalisation
- Bringing all train operating companies into state control
- Network Rail to be disbanded in due course
- No proposed changes to rolling stock ownership (remains with private leasing companies)
- Focus on whole industry decision-making to reduce fragmentation
- Aim to generate savings of up to £2.2 billion per year
Key Considerations and Potential Challenges
- Overlap between GBE, NWF, and UKIB needs to be addressed
- Clarity required on GBE's role in "public ownership of energy"
- Success of GBE dependent on strategic clarity and coordination
- Defence spending increase subject to economic conditions
- Details of railway reforms yet to be fully outlined
Real Estate
- Planning Reform: Streamlining planning processes to accelerate infrastructure projects and housing development.
- Housing Target: Aim to build 1.5 million homes over the next parliament.
- Data Centres: Removing planning barriers for new data centres to support AI and tech industry growth.
- Infrastructure Strategy: Developing a new 10-year infrastructure strategy ie extend time horizons to provide greater stability for long-term investment
- Devolution: Shifting power away from Westminster to support regional growth, including new powers for mayors over transport, skills, housing, planning, and employment support.
- Town Growth Plans: Developing new plans for towns across the country, though specific funding is not outlined
- Seek to introduce a ban on Section 21 ‘no fault’ evictions in the first 100 days; proposal aligns with several amendments tabled by Labour while in Opposition to the Renters (Reform) Bill (RRB) to strengthen tenants’ rights. The original RRB was lost after the election was called
- Leasehold Reform: the Leasehold and Freehold Reform Act 2024 received Royal Assent during the ‘wash-up’ period of the last parliament. It will be up to the Labour Party to bring its provisions into force. However, those did not include proposals for commonhold to be the default tenure. It remains to be seen if Labour in government will introduce or otherwise tackle that provision.
- Build 1.5 million new homes
- Introduce a permanent mortgage guarantee scheme for first-time buyers
Around 13 October: main fiscal event
If the first 100 Days’ clock started ticking on 5 July and included weekends and bank holidays it would reach 100 on 13 October – a Sunday! Counting weekdays only it would continue to run until 22 November. Somewhere within that window is likely to be a full Departmental Spending Review and full Budget with OBR analysis, followed by Budget Resolutions and draft legislation likely to be enacted (post-consultation) in a Finance Act in Q1 2025. Those will set the fiscal framework for the whole of the Parliament. Given the ambition of Labour’s programme including relatively short timescales (eg net zero electricity by 2030) it is likely they will want the Budget around the early part of that window. We may also see the business tax roadmap promised in the first six months of the new Parliament, intended to provide businesses with greater certainty on fiscal measures over the life of the new Parliament.
See the earlier section on Tax/fiscal and Monetary Policy.
Listen back to our election podcasts
In the run-up to the election, we produced a series of podcasts, anticipating the likely trajectory of a Labour government. You can listen back to them below.
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