The Shadow Workforce

DHCW's published annual accounts for 2023/24 disclose that at least 23 individuals were engaged as off-payroll workers earning £245 or more per day. Not one of them is named in any public document. Not one has been called to give evidence before any Senedd committee. Not one has a publicly available biography, job description, or performance record. They make operational decisions, influence procurement, and spend public money — and no one outside DHCW knows who they are.

The Numbers

The off-payroll worker disclosure in DHCW's 2023/24 annual accounts is a statutory requirement. All public bodies must report the number of individuals engaged through off-payroll arrangements above a defined daily rate threshold (£245 per day, equivalent to approximately £63,700 per year on a full-time basis).

DHCW reports at least 23 such individuals.

The £245/day threshold is a reporting floor, not a typical rate. For the kind of roles that off-payroll workers fill at a digital health organisation — interim programme directors, technical architects, transformation consultants, commercial advisers — market rates in 2024/25 range from £500 to £800 per day, and in some specialist areas exceed £1,000.

The collective cost of 23 off-payroll workers depends on their actual daily rates and the duration of their engagements. Conservative and moderate estimates produce the following range:

• Lower bound: 23 workers at an average of £300/day for an average of 220 working days = approximately £1.5 million per year
• Mid-range estimate: 23 workers at an average of £550/day for an average of 220 days = approximately £2.8 million per year
• Upper estimate: 23 workers at an average of £700/day for an average of 220 days = approximately £3.5 million per year

Some engagements will be shorter-term; some rates will be higher. The plausible range is £1.5 million to £4.5 million per year in off-payroll costs, separate from DHCW's reported consultancy expenditure and separate from its permanent payroll.

To put this in context: DHCW's total reported consultancy expenditure in 2023/24 was £0.757 million. The off-payroll workforce likely costs two to six times more than the organisation's declared consultancy spend.

One Confirmed Example

Extensive searching of public records — including Companies House filings, FOI responses, published accounts, board papers, and media coverage — has identified only one off-payroll worker at DHCW by name.

Stuart Davies was engaged as an interim consultant through his personal service company, Hafod Interim Limited (Companies House registration available). The identification was possible only because of corporate filings that linked his consultancy company to work described in connection with DHCW.

This is the sole publicly identifiable off-payroll worker out of at least 23.

The question follows naturally: if only one of 23 off-payroll workers can be identified through diligent searching of public records, what about the other 22? Who are they? What roles do they fill? What decisions do they make? What are they paid? How long have they been engaged? Who approved their engagement? And who evaluates their performance?

DHCW's published accounts do not answer any of these questions. No other public document does either.

The Accountability Gap

Off-payroll workers occupy a structural gap in public sector accountability. They are not employees, so they are not subject to the same performance management frameworks, disciplinary procedures, or codes of conduct that apply to permanent NHS staff. They are not board members, so their names do not appear in governance disclosures. They are not contractors in the traditional sense — procured through formal competitive tenders with published contract values — so they do not appear in procurement records.

Yet they occupy roles with significant decision-making authority. In a digital health organisation, off-payroll workers commonly fill positions such as:

• Programme directors responsible for multi-million-pound delivery programmes
• Technical architects making design decisions that lock the organisation into particular platforms and suppliers for years
• Commercial advisers involved in procurement evaluations and contract negotiations
• Transformation leads managing organisational change programmes

These are not peripheral roles. These are the people doing the work that DHCW exists to do. And because they sit outside normal employment governance, they operate in a space where the usual mechanisms of scrutiny — job descriptions on the website, annual appraisals subject to FOI, disciplinary procedures, whistleblowing protections — do not straightforwardly apply.

What the Accounts Actually Report

DHCW's 2023/24 annual accounts report workforce numbers across several categories:

• Permanent staff: the main workforce, reported in the staff numbers note
• Agency staff: 8 individuals, engaged through staffing agencies
• Seconded staff: 12 individuals, on loan from other NHS bodies
• Off-payroll workers (£245+/day): at least 23 individuals

The 23 off-payroll workers are reported in a separate disclosure from agency staff. This distinction matters. Agency workers are engaged through recruitment agencies that take responsibility for employment obligations. Off-payroll workers at the £245+/day threshold are typically engaged through personal service companies (PSCs) or small consultancy firms — arrangements where the individual is, in practical terms, a self-employed contractor providing services directly to DHCW.

This means they are not covered by agency worker regulations. They are not on DHCW's payroll. Their IR35 tax status — whether they should be treated as employees for tax purposes — is determined by DHCW, and the accuracy of those determinations is itself a matter of public interest.

The Consultancy Classification Question

DHCW reported total consultancy expenditure of £0.757 million in 2023/24. This is the figure that appears in the accounts under the consultancy heading and would be the number cited in any FOI response about consultancy spending.

But the classification boundary between "consultancy" and other categories of expenditure — programme costs, project delivery, technical services — is a matter of organisational discretion. An engagement that one body classifies as consultancy, another might classify as programme expenditure or technical support services. The effect is that the true cost of external advisory and delivery capacity can be distributed across multiple budget lines, making it invisible in any single disclosure.

If 23 off-payroll workers at senior rates collectively cost £2-4 million per year, and only £0.757 million appears under "consultancy," the remaining cost is being classified under other headings. This is not necessarily improper — classification rules permit it — but the effect is that the public sees a consultancy figure that dramatically understates the organisation's actual dependence on external, non-permanent workers.

The Comparison

The absence of transparency around off-payroll workers is not an inherent feature of public sector governance. It is a choice.

NHS England requires trusts and arm's-length bodies to publish off-payroll worker data through annual reporting requirements that go significantly further than the disclosures DHCW provides. Individual NHS trusts in England name consultants engaged above defined thresholds. Cabinet Office transparency requirements for UK Government departments include publication of spending data that allows off-payroll engagements to be identified.

Wales has no equivalent practice. DHCW reports the number of off-payroll workers above the threshold. It does not name them. It does not disclose their roles. It does not disclose their individual daily rates. It does not disclose the duration of their engagements. It does not disclose who approved their engagement or on what basis.

The result is a shadow workforce — dozens of individuals, spending millions of pounds of public money, making decisions that affect every health board in Wales — operating entirely outside public view. They are accountable to whoever hired them inside DHCW, and to no one else.

Twenty-three people. Earning at least £245 a day each. Collectively costing the Welsh public an estimated £1.5 to £4.5 million per year. Not one named. Not one called to account. Not one visible to the public whose health service they are supposed to be building.

This is not a staffing arrangement. It is the architecture of unaccountability.