posted 19th May 2026
Most leaders, if asked whether they expect their decisions to be scrutinised, would say yes. They are aware that boards review, that regulators examine, that institutions have processes for challenge and accountability.
Scrutiny, in this sense, is an understood feature of senior leadership.
What is less well understood — and what experience working alongside leaders under pressure consistently reveals — is what scrutiny actually looks like when it arrives. How it feels. What it exposes.
And why leaders who considered themselves prepared so often find that they were not.
The forms scrutiny takes
Scrutiny is not a single thing. It arrives in different forms, at different speeds, with different consequences, and it is rarely announced in advance.
Formal institutional scrutiny — a board review, a regulatory examination, a public inquiry, a parliamentary committee — is the most visible form. It comes with procedures, timelines, legal frameworks, and often legal representation. It is the form most leaders have in mind when they think about accountability. It is also, in many cases, the last point at which preparation is still possible.
Internal scrutiny is often more immediate and more frequent. A chair questioning a recommendation. A non-executive pressing on an assumption. An audit committee examining a process. A successor reviewing the decisions of their predecessor. Internal scrutiny lacks the formality of external examination, but it has its own pressures: the exposure is visible to people whose opinion matters, the relationships involved are ongoing, and the damage to standing and credibility can be lasting even when there are no formal consequences.
Retrospective scrutiny is perhaps the most disorienting form. A decision made under significant pressure, in circumstances that felt clear at the time, is examined months or years later by people who have access to information that was not available when it was made, who are operating without the time constraints that shaped it, and who are evaluating it against an outcome that is now known. The leader who made the decision is in the position of explaining a past context to people who did not experience it and may not be inclined to give it much weight.
Reputational scrutiny — through media, professional networks, or institutional reputation — operates outside formal processes but can have consequences that outlast them. It is often the form leaders are least equipped to manage, partly because it is least amenable to formal response, and partly because it tends to compress complex decisions into simple narratives.
What scrutiny exposes
Scrutiny does not typically expose dishonesty or incompetence, though it does that too. More commonly, it exposes the normal features of decision-making under pressure that were never intended to be visible: the informality of the process, the ambiguity of ownership, the assumptions that were never written down because they seemed obvious at the time.
It exposes the decisions that were made collectively but attributed to no one specifically. The recommendations that became decisions without a clear moment of commitment. The risks that were known about, discussed informally, but never formally surfaced or recorded. The mandate that was interpreted broadly because the circumstances seemed to require it, without explicit authorisation for that interpretation.
It exposes the distance between how a leader experienced a decision — the pressure they were under, the information they had, the constraints they were operating within — and how that decision appears in the record, which is invariably flatter, simpler, and more damning than the reality.
This is not a failure of integrity. It is a failure of process — and it is extraordinarily common.
Why leaders are rarely ready
There are several reasons why leaders find themselves unprepared for scrutiny despite expecting it.
The first is timing. Scrutiny typically arrives after the fact, examining decisions that were made under conditions of urgency and uncertainty. The natural focus during those moments is on making the decision, not on ensuring it is made in a way that will be demonstrable later. The work of accountability — clarifying ownership, testing assumptions, documenting reasoning — feels, in the moment, like a distraction from the work of deciding.
The second is context. Leaders operate within their context with a density of information, relationship, and institutional understanding that is invisible to those examining their decisions from the outside. What felt self-evident at the time requires detailed explanation in retrospect. What seemed like reasonable judgment looks, without context, like an unexamined assumption.
The third is the nature of collective decision-making. Most significant decisions are not made by a single leader at a single moment. They emerge from processes involving multiple people, multiple conversations, and multiple iterations. When scrutiny arrives, the question of who decided what — and on what basis — is often genuinely difficult to answer, even for those who were involved.
The fourth is the absence of independent challenge. Leaders who have not had their decisions tested before they were made have no account of that testing to offer. When scrutiny arrives and asks what challenge was applied, the honest answer is often that the challenge came from people with a stake in the outcome — which is precisely the challenge that scrutiny is designed not to accept.
The preparation that is still possible
Scrutiny cannot always be anticipated, and its timing cannot be controlled. But the quality of preparation for it can be addressed — not retrospectively, but in the ordinary course of leadership, before any specific examination is in view.
That preparation involves establishing, as a matter of habit rather than crisis response, the conditions that scrutiny will look for: clarity of authority and mandate, tested assumptions, visible accountability, and an ongoing record of independent challenge.
It is less about protection and more about discipline. A leader who has exercised genuine independent accountability over their decisions — who can account for how they were made, who challenged them, and what was considered — is not a leader who was preparing for scrutiny. They are a leader who was doing their job well.
The difference is that when scrutiny arrives, they are ready for it.
What the new law adds
The Public Office (Accountability) Bill creates new and specific forms of formal scrutiny that public sector leaders must now anticipate. It introduces an "always-on" duty of candour and assistance — requiring public officials to proactively notify inquiry leads of relevant information, to provide all reasonable assistance, and to correct errors or omissions when identified. Failure to comply, where intentional or reckless, carries criminal sanctions.
This changes the character of formal scrutiny for those in scope. It is no longer sufficient to respond to scrutiny when it arrives. The duty of candour requires a leader to have operated, throughout their tenure, in a way that would satisfy an examiner asking: did you act with transparency and frankness? Did you draw attention to what was relevant? Did you correct what was wrong when you knew it?
These questions cannot be answered at the point of inquiry. They can only be answered by the quality of the practice that preceded it.
Fahm & Co. provides independent accountability partnerships to senior leaders in complex, high-trust environments. Enquiries are confidential and can be made at www.fahm.com/contact
