by Peter Kahl, 11 August 2025
Today, I formally reported the Higher Education Policy Institute (HEPI) to the Charity Commission for England and Wales.
The full complaint letter is available on Substack, GitHub, and Scribd.
I am an outsider to the UK higher education ecosystem — I hold no post in a university, think tank, or sector body — but I have watched HEPI’s reach and influence over national policy debates grow for years. Its publications are cited in Parliament, its commentary shapes media narratives, and its trustees sit in positions of authority across the sector.
With influence comes obligation. Trustees are bound not only by fiduciary duties under the Charities Act 2011 and Charity Commission guidance CC29 (Conflicts of Interest), but also by epistemic duties: the responsibility to ensure the public has accurate, complete, and timely information about who governs and influences the organisation.
In my complaint to the Commission, I set out three failures that strike at the core of these duties:
- Inaccurate trustee records — Trustees still listed on the public register nearly a year after stepping down.
- Incomplete declarations — Trustees with multiple other governance roles listed as having “No other trusteeships” despite clear public evidence to the contrary.
- Reactive, not proactive, transparency — Corrections made only after an external challenge.
This is not an administrative quibble. It is about the public’s right to know who is in the room when an organisation with national influence makes its decisions. That is as much an epistemic obligation as a fiduciary one.
In last Friday’s post, When the Gatekeepers Hold the Keys, I described how epistemic gatekeeping operates in parliamentary procedure and why I had written to the Education Select Committee — and to the Clerk of the House, Tom Goldsmith — about a placement by a Commons clerk at the Higher Education Policy Institute (HEPI). That post set out my concern: not an accusation of bias, but a demand for transparency when those with procedural power have recent ties to sector bodies under scrutiny.
Today, I received a reply from the Clerk of the House of Commons. While affirming that such placements are generally regarded internally as legitimate developmental activities, he has also asked the Managing Director of the Select Committee Team to examine the specific instance I raised and to respond formally once that review is complete.
This is significant. It means the concern has moved from correspondence into an internal process of review. It is a reminder that even from outside the parliamentary system, scrutiny — when it is grounded in evidence and law — can open the door to formal examination of practices that would otherwise remain invisible.
If an independent think tank’s governance structures are opaque, the public is left to guess whether its output truly serves the public interest or subtly advances undisclosed agendas.
In The Epistemic Architecture of Power {Kahl 2025}, I explored how institutional opacity distorts the flow of knowledge and shields decision-makers from accountability. This case is almost a live illustration of those arguments:
The architecture here is a mesh of trustee networks, unrecorded roles, and selective transparency.
The power is the ability to shape national policy narratives without the public being able to map the influences at work.
Demanding that this architecture be visible is not hostility — it is the bare minimum any citizen should expect of those who govern in the public’s name.
- The Charity Commission now has the details of my concerns about HEPI.
- If further responses from HEPI’s trustees are unsatisfactory or absent by my stated deadline, I will update the Commission accordingly.
- I will continue publishing all relevant correspondence and evidence, to keep the process as open to public scrutiny as possible.
Accountability is not a favour an organisation grants the public — it is a duty. And for those entrusted with shaping the landscape of UK higher education, it is a fiduciary-epistemic duty that must be lived, not just written down.
- The complaint letter to the Charity Commission
- Evidence Brief – HEPI Trustee Record Inaccuracies, Undeclared Trusteeships & CC29 Non-Compliance
Peter Kahl, ‘Reporting HEPI to the Charity Commission: An Outsider’s Demand for Fiduciary-Epistemic Accountability’ (Lex et Ratio Ltd, 11 August 2025) <https://github.com/Peter-Kahl/Reporting-HEPI-to-the-Charity-Commission>
First published in Great Britain by Lex et Ratio Ltd on 11 August 2025.
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