Project Application Registration Assessment Framework Updates

24 Oct 2022

As the regulator of the Landfill Communities Fund (LCF), ENTRUST provides HMRC with independent assurance that LCF funds are spent in accordance with the Landfill Tax Regulations 1996 (Regulations).

Following discussions in relation to several cases where Environmental Bodies (EBs) had failed to comply with the Regulations, ENTRUST and HMRC have decided it would be appropriate to undertake a more robust scrutiny of project applications.

As part of our overall ‘coaching to compliance’ ethos, we recognise the importance of communicating these additional changes to stakeholders. We will therefore be updating our project registration process to:

  • Provide a more robust and challenging assessment framework;
  • Support EBs in submitting applications, which will be registered on submission;
  • Allow EBs to submit more complex and innovative projects; and
  • To mitigate the risk that a project will not be compliant once it has been delivered.

Based on our knowledge and experience in registering projects, we believe these updates will mean no changes to the current process for the majority of project applications.

However, as we outlined above, for certain projects the registration process has been updated to accommodate the following changes:

  • Financial Information – ENTRUST requires EBs to provide a minimum level of financial information, so that we are able to assess if a project application will be compliant with the Regulations. This information is also used to assess a project’s compliance upon completion. EBs should therefore be aware that they may be asked for more in-depth financial information, for example, a quotation or budget sheet, especially when the value of the item is high. If, for whatever reason, an EB is unable to provide detail in the cost breakdown, they are advised to attach their preferred quotes/budgets to the project application to help avoid any unnecessary delays to approval.
  • Income Derived – In completing our 2021/2022 Value for Money (VfM) report, we identified an issue regarding the quality of the information on the income derived estimate. To address this, we now require EBs’ to provide the amount of additional income they believe will be generated following project delivery;
  • Higher Risk Projects - ENTRUST has developed a high-risk framework, which helps us identify more complex proejcts and provide them with the appropriate level of scrutiny. Generally speaking, if a project application falls under the criteria of a higher risk project, the level of scrutiny will be proportionally increased. EBs should therefore recognise this requirement when it comes to developing a timeline for project works on more complex projects, especially those which require proportional registration or are of high value; 
  • Public Access Statement – From our breach management work, we have identified that a number of public access statements submitted to ENTRUST in recent months have not been 100% accurate. To address this issue, we may therefore require, as part of the public access statement, documented evidence of community engagement or a supporting business case, where projects are on restricted grounds to demonstrate the wider community requirement for and use of a public amenity; and
  • Equipment Purchases – In carrying out our assurance work, we have also identified a rise in equipment purchases. We have therefore developed a framework to ensure that any equipment purchases are not restricted to a specific user group as is set out in the Guidance Manual.

If you would like to discuss any of these developments, please do get in touch by emailing or calling 01926 488 300.