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How do public inquiries operate in other countries?

Public inquiries, or similar types of investigations, exist in many countries. While in some countries the Parliament can commission its own Parliamentary Committees of Inquiry, this briefing focuses on inquiries commissioned by government in four countries, each with a different system for public inquiries: New Zealand, the Netherlands, Sweden, and Ireland.

In the United Kingdom, inquiries are established by a government minister and can be either statutory (established under the Inquiries Act 2005) or non-statutory. The median final cost of a statutory inquiry is £9.1 million (£11.5 million in 2026 prices), and the median duration of a statutory inquiry is 1,313 days (three and a half years).

More information about how inquiries operate can be found in the Commons Library research briefing on Public inquiries. Key facts about each inquiry can be found in the Commons Library data dashboard on Public inquiries established under the Inquiries Act 2005.

How do public inquiries work in other countries?

New Zealand

In New Zealand, public inquiries were reformed by the Inquiries Act 2013 to make the system more efficient and flexible. There are now three tiers of statutory inquiries, depending on the scale of the issue being investigated.

Government inquiries, which are established by individual ministers to handle the narrowest and most immediate issues, take on average 10 months to report, with an average cost of $3.5 million (£1.5 million).

Public inquiries, which are established by the Governor-General on the recommendation of the government for broader or more serious issues, take on average 18 months, with an average cost of $3.9 million (£1.7 million).

Royal Commissions, which are established by the Governor-General to handle the most serious issues of public importance, take on average 20 months, with an average cost of $16.4 million (£7.2 million), excluding one outlier.

The Netherlands

In the Netherlands, the Dutch Safety Board (or OVV) operates as an independent body to investigate incidents and accidents that threaten public safety. The OVV has a statutory duty to investigate incidents in four sectors (aviation, shipping, industry and rail), but ministers, mayors and individual citizens can request investigations into other sectors.

Under the Dutch Safety Board Act 2005 (PDF), the OVV must conduct investigations as efficiently as possible and in the shortest possible time. Under the Turnaround Times project in 2022, the OVV aimed to improve their efficiency so that investigations could be completed within one year.

Sweden

In Sweden, inquiries are established by the Cabinet and can be run either by a commission of inquiry (led by a chair, sitting with one or more commissioners) or by a special investigator sitting alone. The Government Offices set the budget for each inquiry, and the Commission Service, a special unit within the Government Offices, provides administrative support.

Between 1990 and 2024, the average length of an inquiry in Sweden was 23.8 months (just under two years).

Ireland

In Ireland, there are two equivalents of public inquiries: tribunals of inquiry and commissions of investigation. Tribunals of inquiry are established, and report to, by the Oireachtas (the Irish Parliament), while commissions of investigation are established by government order.

According to reporting by the Irish Times, 10 tribunals of inquiry and 17 commissions of investigation have been held since the late 1990s, with an average cost of €22 million per inquiry (£18.5 million) and an average duration of more than five years.

What are the differences between public inquiries in the UK and in other countries?

Budget and maximum duration

In countries including New Zealand and Sweden, ministers set a budget and timeline at the outset on an inquiry. While this has been done in the UK in 2026 with the Independent Inquiry into Grooming Gangs, it has not previously been common practice for an inquiry budget to be set by a minister in advance.

Administrative support from a standing unit

A large part of an inquiry’s costs in the UK come from staffing costs for a secretariat, as well as administrative costs such as office space, IT and telecommunications infrastructure and record management.

In countries including New Zealand and Sweden, a dedicated unit within a government department can provide administrative support, while in the Netherlands the Dutch Safety Board is set up as a permanent body and provides its own administrative support.

Different tiers of public inquiry

In the UK inquiries can be either statutory or non-statutory, but in practice both types of inquiries operate similarly. A public inquiry operates under the same framework whether it is established to investigate a single incident (such as the Inquiry into the death of Bernard (Sonny) Lodge, which cost £0.4 million and lasted 295 days) or to investigate the broadest and most serious issues of public concern (such as the Independent Inquiry into Child Sexual Abuse, which cost £194.6 million and lasted for eight years).

In contrast, New Zealand offers three tiers of public inquiries depending on the breadth of the issue being investigated, while Sweden and Ireland both have multiple pathways for setting up an inquiry.

Requirement to justify recommendations

In the UK, there are no restrictions on the conclusions that an inquiry report can draw or the recommendations it can make. There is also no formal mechanism for following up inquiry recommendations and seeing whether they have been implemented by government.

In contrast, in Sweden commissions of inquiry can be required to provide impact assessments and costs estimates of any recommendations they make.