Which rules apply depends on one number: a council's gross annual income or expenditure, whichever is higher.
- £25,000 or less - the Transparency Code for Smaller Authorities applies. Seven categories, fixed deadlines, and it must be on a free public website. Note "not exceeding": turnover of exactly £25,000 is inside the Code. Turnover is "the higher of an authority's gross income for the year and its gross expenditure for the year" (Code, para 6).
- Above £25,000 - that Code stops applying and, perhaps surprisingly, nothing replaces it for minutes and agendas. The accounts duties are stricter; the meeting-paper duties largely disappear.
- Above £6.5 million - a second regime switches on and the council must publish Part 2 of the Local Government Transparency Code 2015. It is a substantial list, and it still says nothing about minutes or agendas.
England only. General guidance, not legal advice.
If turnover is £25,000 or less
The Smaller Authorities (Transparency Requirements) (England) Regulations 2015 make the Code legally binding: an authority to which the Code applies "must publish the information specified in the Code in the manner and form and on the occasions specified in the Code" (regulation 2(1)). It's not best practice; it's a legal duty with a statutory instrument behind it.
The Code lists seven things, and only seven:
| What | When |
|---|---|
| All items of expenditure above £100 | Annually, by 1 July following the accounting year |
| End of year accounts | Annually, by 1 July |
| Annual governance statement | Annually, by 1 July |
| Internal audit report | Annually, by 1 July |
| List of councillor or member responsibilities | Annually, by 1 July |
| Details of public land and building assets | Annually, by 1 July |
| Minutes, agendas and meeting papers of formal meetings | See below |
For each item of expenditure above £100 the council must publish the date it was incurred, a summary of its purpose, the amount, and any VAT that cannot be recovered. Note that this is an annual publication, due by 1 July - the Code does not require monthly or quarterly spend reporting.
One drafting point that matters. Paragraphs 10, 13, 29 and 30 all say smaller authorities "should publish". That reads like advice - but SI 2015/494 reg 2(1) requires publication "in the manner and form and on the occasions specified in the Code", which converts it into a duty. Don't let anyone argue the Code is optional because of the word "should".
For meetings, the Code requires:
"Smaller authorities should publish the draft minutes from all formal meetings (i.e. full council or board, committee and sub-committee meetings) not later than one month after the meeting has taken place."
"Smaller authorities should also publish meeting agendas, which are as full and informative as possible, and associated meeting papers not later than three clear days before the meeting to which they relate is taking place."
Note "all formal meetings" - committees and sub-committees too, not just full council.
It must be on a website, free of charge. Paragraph 32: the information "must be published on a website which is publicly accessible free of charge". A noticeboard doesn't discharge this, and neither does anything behind a login or a fee.
The Code then offers the billing authority's website (district, London borough or unitary) as an illustration - "one way that this requirement could be achieved could be". Treat it as an example rather than a guaranteed safe harbour, because that is how it is drafted.
A note on the Code's age. It was issued in December 2014 and has never been revised, so it still refers to the "Annual Return" (now the AGAR) and to the Data Protection Act 1998 (now the DPA 2018 and UK GDPR). The substance of what must be published is unaffected.
If turnover is above £25,000
Here's where the position becomes counter-intuitive.
The Transparency Code for Smaller Authorities stops applying. The obvious candidate to replace it is the Local Government Transparency Code 2015, and the answer there turns on two different thresholds which are easy to run together.
The Code's own scope. Its definition of "local authority" includes "a parish council which has gross annual income or expenditure (whichever is the higher) exceeding £200,000". Above £200,000 a council is within the Code's stated scope.
The statutory duty is separate, and cuts in much higher. The duty comes from the regulations rather than from the Code itself. SI 2015/480, regulation 2(1) applies the duty to publish Part 2 to every authority to which the Code applies, "other than a parish council whose gross annual income or expenditure (whichever is the higher) is £6.5 million or less".
| Turnover | Position |
|---|---|
| £25,000 or less | Transparency Code for Smaller Authorities applies |
| £25,000 to £200,000 | Outside both codes |
| £200,000 to £6.5 million | Within the 2015 Code's scope, but reg 2(1) removes the duty to publish Part 2 |
| Above £6.5 million | Within the Code, and the Part 2 duty applies |
The third row is worth stating precisely. It is not that the 2015 Code has nothing to do with a £1 million town council - it is that the enforceable duty does not reach it. The practical effect is the same, no obligation to publish Part 2, but the reasoning matters if anyone argues the point.
What still binds a council
Accounts do - and these are the duties that expressly name a website. Under regulation 15(2) of the Accounts and Audit Regulations 2015 the responsible financial officer must "publish (which must include publication on the authority's website)" the statement of accounts, the annual governance statement, and the notice of the period for the exercise of public rights. Regulation 13(1) then requires publication - again including on the website - of the audited statement and governance statement by 30 September following the year end, with a five-year availability requirement in reg 13(2)(b). A Category 2 authority with exempt status follows reg 13(4) instead.
If a council has no website of its own, reg 2(5)(a) allows publication on any website, provided it is "accessible by any member of the public without registration or payment".
(Regulation 12 is about signing and approving the accounts. It contains no publication duty, so don't cite it for one.) Public inspection rights over the accounts run in a separate 30-working-day window each year - see who can see parish council minutes.
Meeting notices do. Three clear days before a meeting, notice of the time and place must be fixed "in some conspicuous place in the parish" (LGA 1972, Schedule 12, paragraph 10(2)). That is a physical notice duty - it is not an agenda-publication duty and it says nothing about a website. See three clear days' notice.
Inspection rights do. Any local government elector for the parish may inspect the council's minutes and make their own copy (LGA 1972, s.228(1)) - including minutes of business taken with the public excluded. See who can see parish council minutes.
The publication scheme does. Every public authority must adopt a publication scheme and, under FOIA s.19(1)(b), publish information in accordance with it. Section 19 itself never mentions minutes or agendas; what puts them in scope is the scheme the council adopts. The ICO's model scheme and its template guide for parish councils put minutes and agendas in Class 4, "How we make decisions", covering the current and previous council year as a minimum - but the template says "hard copy or website".
So the duty is statutory and the content is regulator guidance. That is the honest way to describe it: s.19 compels a council to publish in accordance with a scheme, and the scheme is where the substance lives.
Officer decisions do. Under the Openness of Local Government Bodies Regulations 2014, written records of certain delegated officer decisions, and their background papers, must be available for public inspection at the council's offices and on its website if it has one (reg 8(1)). Note the limit: reg 7(2) reaches only decisions delegated to an officer. It says nothing about council, committee or sub-committee minutes, so it does not fill the gap for meeting papers.
If a council is above £6.5 million: Part 2 of the 2015 Code
Very few parish and town councils are. If a council is, this is a real and substantial duty - and one limiting provision does much of the work in its favour:
"This Code only applies to local authorities in relation to descriptions of information or data where that type of local authority undertakes the particular function to which the information or data relates."
So a council publishes what relates to functions it actually has. For a town council that means:
Quarterly
- Every item of expenditure over £500 - date, department, beneficiary, purpose, amount, recoverable VAT and merchant category. Note the contrast with the smaller-authorities Code, where the figure is £100 and publication is annual.
- Procurement - every invitation to tender over £5,000, and every contract or agreement over £5,000, with supplier, value, dates, and whether the supplier is an SME or a voluntary, community or social enterprise organisation.
- Government Procurement Card transactions, if the council holds any.
Annually
- Land - everything the council owns or controls, with UPRN, address and postcode.
- Grants to voluntary, community and social enterprise organisations. This one is easy to overlook: most councils of that size give grants.
- Organisation chart for the top three levels, with grade, title, department and salary bracket.
- Senior salaries - the number of employees paid at least £50,000, in £5,000 brackets, with responsibilities and bonuses for everyone above that figure.
- Pay multiple - the ratio between the highest taxable earnings and median earnings across the whole workforce.
- Constitution. The Code says local authorities must publish it. A parish council has no constitution in the Local Government Act 2000 sense, so read this as the council's standing orders and financial regulations.
- Parking account and number of parking spaces, if the council runs off-street parking. Some town councils do.
- Trade union facility time, if the council has recognised representatives.
- Fraud - counter-fraud staffing, spend, and cases investigated.
- Social housing asset value needs a Housing Revenue Account, so in practice never.
Once: details of existing waste collection contracts.
Two things to watch. Regulation 2(2) defines "the Code" as the one "issued on 27th February 2015", while the version on GOV.UK has been revised since, most recently in January 2025 - so work from the current published text rather than hunting for the original. And the Procurement Act 2023 overlaps with the procurement items above: MHCLG published guidance in January 2025 on reconciling the two sets of publication requirements, and it will be needed alongside Part 2.
So: must a larger parish council put its minutes online?
Strictly, no. There is no general statutory duty on an England parish or town council above £25,000 to publish minutes, agendas or meeting papers on a website. The smaller-authorities Code's duty falls away and nothing replaces it - and that holds however large the council is, because Part 2 of the 2015 Code does not cover minutes or agendas either.
Every reason of practice points the other way, though. The sector's own guidance treats minutes as belonging in the minute book and on the council's website. The publication scheme commits the council to routine proactive publication, and the ICO expects website publication where that's within the council's capability. Refusing a request by saying "come and inspect it at the office" is where councils end up on the wrong side of an ICO decision notice. And a council that publishes less than the smallest parish in the district will be asked why.
The honest formulation: above £25,000 this is a choice rather than a duty, and the sensible choice is to publish to the smaller-authority standard anyway.
Two changes in the last year
-
The audit threshold rose from £6.5m to £15m, by SI 2025/1026 with effect from 17 September 2025. Read s.6(2) carefully though: £6.5m still governs financial years beginning on or before 1 April 2024, and £15m only years beginning on or after 1 April 2025.
This did not move the £6.5m figure above. The carve-out in SI 2015/480 reg 2(1) is a separate, hard-coded number, and it is untouched. Nor does it affect the £25,000 in the smaller-authorities Code. Three thresholds, three different jobs.
-
"Smaller authority" has been renamed "category 2 authority" by the English Devolution and Community Empowerment Act 2026, s.96, in force 15 July 2026. It is a word substitution plus a reading rule; no qualifying condition and no duty changed.
It does create a trap worth knowing. "Category 2 authority" now means two different things: under LAAA s.6 it means turnover of £15m or less, while under reg 2(1) of the Accounts and Audit Regulations 2015 it has meant, since 2015, a smaller authority that has not opted into full audit. Same words, both live. If a document uses the term, check which one it means.
A publication checklist
Whatever the council's turnover:
- Publication scheme adopted, and actually followed
- Agendas out at least three clear days before, and the notice physically displayed
- Draft minutes published within a month of the meeting - committees too
- Approved minutes replacing the drafts
- Accounts, AGAR and governance statement published to the audit timetable
- Notice of the public rights inspection period
- Councillor responsibilities and asset details up to date
- Everything published in an accessible format - see accessible agendas and minutes
- Accessibility statement on the website
Publishing without the admin
Most of this is the same handful of documents appearing in the right place at the right time. In CouncilPapers, committing an agenda publishes it and notifies members in one step, and minutes move from draft to approved on the public pages automatically - with a WordPress plugin if the council's site runs on WordPress. See publishing and switching versions, or start a free 45-day trial.
Last reviewed 26 September 2026. General guidance for councils in England, not legal advice.
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