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I oppose these changes and I am generally very supportive of FoI as a means of holding public bodies to account. However the issue of publication of the risk registers makes me nervous.

There is an unjustifiable and a justifiable reason for witholding the register.
If risk has been poorly managed, either because risks have not been identified or, more significantly, if risks have been identified but not mitigated, this should be transparent and is not a justifiable reason.

Journalists and politicians have little experience of risk management and cannot differentiate btween well managed and poorly managed risk. Many will use the simple fact that a risk has been identified as a club to beat the government. This raises a serious danger that publication will undermine recent progress in getting Civil Servants to do proper risk management.

The answer is surely to obtain external quality assurance of the risk register and publish that.