The arrival of generative AI has undoubtedly changed how individuals engage with public services. What was once a short email or straightforward challenge can now arrive as a lengthy, highly structured submission complete with legal references, procedural arguments and demands for escalation. Public bodies across the UK are reporting significant increases in the volume, length and complexity of both information requests and complaints.
For Billing Authorities, this development presents both an opportunity and a challenge.
On one hand, AI tools can help ratepayers better articulate legitimate concerns and navigate complex processes. Greater accessibility and engagement should be welcomed where it helps ensure fair outcomes. AI can improve access to justice and assist individuals who may previously have struggled to prepare formal submissions.
However, the growing sophistication of AI-generated representations is also increasing pressure on local authority resources. Complaints and challenges can appear professionally written and legally persuasive, even where they contain factual inaccuracies or incorrect/fictitious case law and legislation. Public bodies remain responsible for properly reviewing and responding to each submission, regardless of its quality or origin.
This is particularly relevant within the Non-Domestic Rates environment, where local authorities are already managing complex legislation, significant financial pressures and increasing scrutiny around decision-making.
The Importance of Process
Councils are increasingly being encouraged to tighten governance arrangements surrounding discretionary decisions and appeals.
Examples of practical steps which can be taken include:
- Ensuring discretionary relief decisions are supported by robust governance and appropriate approvals (including Full Council approval where appropriate).
- Proactively completing Equality Impact Assessments wherever they may be required.
- Making sure that officers representing the authority at the Valuation Tribunal provide evidence of their appropriately delegated authority.
- Following published government guidance consistently and transparently.
These are not simply administrative exercises. They are important safeguards that help to ensure decisions remain defensible when challenged.
As AI lowers the barrier to producing detailed objections and procedural challenges, authorities may find that more scrutiny is directed towards how decisions were made, rather than simply what decision was reached. A technically correct outcome can still become vulnerable if governance processes have not been followed consistently or properly documented.
A well-documented decision-making process can help authorities demonstrate that relevant factors were considered, statutory duties were met and policies were applied consistently. Conversely, gaps in governance, record-keeping or delegated authority may create unnecessary exposure during appeals, complaints or external scrutiny.
A Proportionate Response
Authorities should avoid assuming that AI-generated submissions are inherently flawed or without merit. Indeed, some Councils, Ombudsmen and public bodies (PBs) are themselves exploring how AI can support administrative processes and improve efficiency.
Instead, authorities should focus on maintaining clear governance frameworks, accurate records and consistent decision-making.
Interestingly, some councils have already begun publishing guidance on the use of AI in complaints, warning residents that AI-generated submissions can be unnecessarily complex, legally inaccurate or require additional clarification before they can be properly considered.
This reflects a wider recognition across local government that AI is becoming a permanent feature of the public sector landscape.
Looking Ahead
As AI tools continue to evolve, councils can expect representations, complaints and challenges to become increasingly sophisticated. The authorities best placed to manage this change will not necessarily be those with the most resources, but those with the strongest governance foundations.
For the Non-Domestic Rates profession, the lesson is clear: robust procedures, clear delegations, transparent policies and thorough documentation are no longer simply good practice. They are becoming essential components of effective risk management.
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