Scotland’s council body has formally responded to proposals for six to ten regional authorities and 120 to 160 community authorities, asking ministers to commit that structural changes will proceed only through agreement with existing local government.
Scotland’s council leaders have asked the Scottish Government to commit that major changes to local government will be implemented only through agreement with existing local authorities, setting an early condition around negotiations over the proposed redrawing of the country’s council system.
COSLA adopted the position after council leaders met on 25 September, four days after ministers published an opening proposal built around between six and ten regional authorities and between 120 and 160 smaller community authorities. The organisation says it will participate fully in the reform discussions but has called for evidence, meaningful engagement and agreement between Scottish and local government before significant structural change is made.
Modern Scot examined the Government’s opening model and its historical context on 21 September in John Swinney Signed Scotland’s Local-Integration Reform in 2011. Now He Is Redrawing the System. The COSLA response adds the first collective position from the country’s 32 existing councils to that developing story.
It also makes an important distinction clearer. The Scottish Government has proposed a direction for reform. It has not settled the map, the final distribution of powers, the funding system or the future location of social-care responsibilities. COSLA has agreed to take part in that process. It has not agreed to the model that ministers have placed on the table.
The Government’s opening structure
The September proposal is described by the Scottish Government as an opening proposition rather than a final design.
It envisages replacing the present local-government arrangements with six to ten larger regional authorities and 120 to 160 community authorities. Bespoke arrangements could be considered for Scotland’s island communities. Councillors would continue to be elected at the present ward level and could sit on both the community authority and the corresponding regional authority, while a common regional administrative and corporate structure would support the two levels.
The possible division of responsibilities is beginning to take shape. Regional authorities could assume enhanced responsibility for economic development and business support, housing, strategic planning, employability and elements of transport, while also carrying major existing council functions including waste, cleansing, resilience, regulatory services and education.
Community authorities could take responsibility for more localised decisions including householder planning applications, community planning, licensing, historic-environment matters, greenspace, town-centre regeneration and some leisure, sport and cultural provision. Ministers have also proposed a statutory obligation requiring regional authorities to devolve appropriate functions to the community level.
That creates a system that is simultaneously larger and smaller than the present one: strategic services would move above the scale of most current councils, while other functions would move below them.
The Government has not yet drawn the six to ten regional boundaries. It has not fixed the 120 to 160 community areas. Nor has it produced a completed schedule showing where every statutory function presently exercised by Scotland’s councils would sit.
Those omissions are not administrative details. They determine where decisions are made, which elected body is accountable for them and what staff, assets and budgets must move with the responsibility.
COSLA asks for agreement before implementation
COSLA’s response does not reject reform in principle. Council leaders said the system should evolve where evidence shows that change would improve public services, and they said communities and council employees should be meaningfully involved in the work.
The organisation’s clearest request concerns the authority under which change would proceed.
COSLA said significant changes to local government must be agreed between Scottish and local government and called on ministers to commit that any changes would be implemented only through agreement with existing local authorities.
That is an institutional and political position rather than, by itself, a legal veto. The Scottish Parliament can legislate within devolved competence, and COSLA’s statement does not give each council an independent statutory power to block legislation.
It does, however, establish a clear question for the negotiations now beginning: whether ministers will accept local-government agreement as a condition of the reform programme rather than treating consultation with councils as one part of a process ultimately determined by central government and Parliament.
The distinction is particularly important because the proposed changes reach beyond boundaries. A merger or replacement of authorities also raises questions about ownership of land and buildings, inherited debt, pension liabilities, contracts, staff transfer, council-tax administration, business rates, statutory planning functions, education responsibilities and the future of bodies whose membership or finances depend on the present council map.
None of those issues can be resolved simply by drawing six to ten regions on a map.
Funding cannot be separated from functions
The Scottish Government’s proposal acknowledges that the eventual financial settlement depends on decisions that have not yet been made.
Ministers say the responsibilities that should sit at national, regional and community level must be determined before the corresponding funding arrangements can be designed. That includes decisions about how money is distributed and what revenue-raising powers should be available to future local and regional authorities.
This sequencing is significant. A community authority with substantial statutory duties but little control over revenue would be a different institution from one able to raise and retain meaningful income. A regional authority carrying education, waste, housing and transport responsibilities would require a financial base very different from a body established principally for strategic coordination.
The same problem applies to assets and liabilities. Existing councils own schools, depots, offices, housing, land, vehicles and infrastructure. They also hold debt, employ staff and participate in pension arrangements. If the 32-authority structure is replaced, legislation and transition agreements will have to establish where those responsibilities go.
The Government’s current paper does not provide those answers. It sets the direction in which ministers want the discussion to proceed.
Social care remains outside any settled map
The future of social care and social work adds another unresolved layer.
The Government says all options should be considered in the context of both the proposed local-government structure and its separate changes to the NHS. Ministers have committed to discussing the position with councils, trade unions, healthcare organisations and providers.
That means local-government reform cannot be read independently from the wider public-sector programme now under way. Scotland is simultaneously examining health-board structures, national public bodies, shared digital infrastructure, data exchange and the relationship between national, regional and community decision-making.
A function that leaves an existing council could therefore move in several possible directions: to a larger regional authority, to a smaller community authority, to a national body, or into a structure shared with another part of the public sector.
The Government’s stated objective is to improve services and move decisions to the level at which they can be delivered most effectively. COSLA’s response is focused on who gets to decide what that level should be.
A timetable now runs to the end of the year
The Government wants to reach a shared direction on reform before the end of 2026. It has said early decisions could be capable of informing the first Budget of this parliamentary term.
That leaves only a short period in which ministers and councils must move from broad structures to questions that are considerably more difficult: geography, powers, money, staffing and the legal route to transition.
The timing also places the discussion ahead of the next Scottish local elections, a point COSLA itself has highlighted. Councillors elected to the existing 32 authorities could enter office while negotiations are continuing over the future shape of those authorities.
What has changed since the Government published its proposal on 21 September is therefore not the map. There still is no final map.
It is the negotiating position around it.
Ministers have said their proposal is an opening proposition and that they want common ground. Scotland’s council leaders have now stated the basis on which they want that common ground to be built: evidence, participation and agreement with the local authorities that would be replaced or reorganised.
The next stage will show whether that request becomes part of the Government’s process or remains one side’s position within it.
Sources
- Scottish Government — Public sector reform: proposal, 21 September 2026. Read the proposal.
- COSLA — COSLA respond to Scottish Government plans to reform Local Government, 25 September 2026. Read the COSLA response.
- Scottish Government — Programme for Government 2026 to 2031, 1 September 2026. Public-service reform commitments.
- Modern Scot — John Swinney Signed Scotland’s Local-Integration Reform in 2011. Now He Is Redrawing the System, 21 September 2026. Read the earlier Modern Scot investigation.
