NFRC Says No to CITB Merger Proposal

On June 15, NFRC submitting the following response to the government’s proposal.  

NFRC’s Full Response 

Question 1: Do you agree with the proposal to create a single, unified ITB? 

NFRC's response: No 

NFRC (National Federation of Roofing Contractors) cannot confidently support this proposal. The principle of a unified body is not inherently wrong, but the case for merger has not been made clearly enough for specialist sectors like roofing to feel confident that the merger will address current serious concerns. The consultation does not adequately explain how bringing CITB and ECITB together would resolve the specific, longstanding concerns our members have about the way CITB currently operates. 

Question 2: Key reasons for our answer 

The merger does not address our members' core concerns 

NFRC Member businesses are most concerned with issues of priority, representation, and relevance. Roofing is a specialist sector. The only genuinely sector-specific support CITB has historically provided to our members was through roof training groups which are no longer funded. Everything else CITB offers is organised around where an individual is in their career journey (NEST, employer networks, etc.), rather than around the specific needs of trades like roofing. Merging CITB with ECITB risks creating a larger body with an even broader remit and fewer resources for specialist trades. 

Structural reform risks delaying action the industry needs now 

The consultation acknowledges that the construction sector faces significant and immediate workforce pressures yet the proposed timeframe for establishing a single ITB is two years away. In the interim, both organisations risk being consumed by merger planning rather than delivery. Relationships between the ITBs and industry will be disrupted. Staff uncertainty will affect service delivery. The transition period represents a period of reduced effectiveness at a time when the industry needs more support, not less. 

Also, if CITB's grant processing, employer engagement, and skills delivery can essentially run on autopilot during a prolonged transition, that tells us something important about how much of its current activity is genuinely irreplaceable, and how much of its budget might be being absorbed by internal functions rather than frontline delivery or grant awarding. 

Specialist sector representation will be diluted further 

We are concerned that a larger, unified body will be harder for specialist sectors to influence. The levy consensus process already requires our members to make the case for the roofing sector's interests alongside far larger parts of the industry. A merged ITB, with a wider scope and potentially a reshaped board, risks diluting specialist voices even further. 

The consultation states that a single ITB would 'preserve sector expertise.' We do not see a credible mechanism for this. Assurances without governance structures to back them up are not sufficient. 

The merger is being asked to solve problems it cannot fix 

The Farmer Review identified a need for better strategic workforce planning, stronger KPIs, and a more forward-thinking approach to skills. These are objectives that CITB should already be pursuing independently of a merger.  

Performance is still largely reported in terms of how much levy funding has been distributed, rather than meaningful outcomes for employers or the workforce. A larger merged body will not automatically fix this. This must be a focus of any reform. 

Market intelligence and workforce planning 

The consultation cites improved market intelligence as a benefit of merger. Skills England's remit already includes widespread and total labour market intelligence. It is not clear to us who is currently responsible for the CITB workforce outlook, how that information is gathered, or why it is not more transparent and accessible to industry, nor why collaboration with ECITB is not already standard. These are questions that need answering regardless of whether a merger proceeds. 

  Question 3: Most significant potential benefits of a single ITB 

We acknowledge there are some potential benefits to a unified body: 

1. Reduced duplication in back-office functions and infrastructure, which could in principle free up resource for frontline delivery, though we would want to see clear commitments on how any savings would be reinvested. 
2. A single skills passport, rather than separate CITB and ECITB versions, would be a practical administrative improvement though should not require a full merger. 
3. There is a case for more joined-up planning across construction and engineering construction, particularly for large infrastructure projects where both workforces are needed. 

For these benefits to be realised, the merged body would need a governance structure that adequately represents specialist sectors and SMEs, clear and measurable KPIs tied to outcomes rather than spend, and a commitment to protecting and funding sector-specific training provision. 

Question 4: Most significant potential costs and risks 

1. Loss of specialist sector expertise and provision, particularly for trades like roofing where CITB's tailored offer is already thin and deteriorating and where employer confidence is rock bottom. 
2. Prolonged disruption during transition, with merger planning consuming staff time and leadership attention at the expense of delivery. 
3. Further dilution of specialist employer representation in levy consensus processes and governance. 
4. The risk that merger becomes a structural change that is presented as reform but does not address the underlying issues with how CITB operates and what it prioritises. 
5. We would want to understand how the merger changes funding allocation to reduce expenditure on internal operations, and whether any rationalisation of staffing will be focused on strategic and policy roles or on the employer-facing teams that members directly rely on and utilise. 

Question 5: Alternative approaches to ITB reform  

If the Government proceeds with the merger, we would urge it to do so only alongside reforms that address the substance of what is not working. But we would also ask whether the following alternatives have been sufficiently considered: 

1. Requiring CITB to demonstrate it is fulfilling its legislative obligations before any structural change. The consultation raises this implicitly but does not address it directly. This should happen alongside a review of whether its legislative functions are still appropriate for the modern environment. 
2. Setting CITB meaningful, outcomes-based KPIs as a condition of continued levy authority, independently of any merger. 
3. Reforming CITB's internal governance and board composition to better represent the range of sectors within scope, including specialist trades and SMEs. 
4. Requiring greater transparency on how levy income is spent, including the balance between frontline delivery, employer engagement, and internal functions. 
5. Introduction of a more transparent and employer owned levy system, similar to the principles of the Skills and Growth levy. This gives employers sight of their contribution, as well as their predicted and actual spend.  

 Question 8: Changes to employer activities in scope 

The most significant gap in the ITBs' current scope is pre-16 engagement. Our members consistently tell us that attracting young people into roofing and construction requires engagement long before the age of 16. Career decisions, and career perceptions, are formed in childhood. This has been echoed in a recent report by Alan Milburn. 

The Gatsby Careers Benchmarks make clear that meaningful employer encounters should begin in secondary school. Yet the ITBs' remit effectively prevents them from working with the organisations and schools where this engagement matters most. 

We would urge the Government to review the pre-16 restriction as a matter of priority, regardless of whether the merger proceeds. This is one of the most consistent asks from our members, and it is not addressed anywhere in the current proposal. 

Question 9: Maximum levy period 

We do not have a strong objection in principle to extending the maximum levy period beyond three years, but we are not convinced it would deliver the benefits suggested. 

The construction sector remains cyclical and volatile. Longer levy periods might in theory encourage more long-term workforce planning, but the boom-and-bust dynamics that dominate much of the sector will not be resolved by a longer approval window. There is a real risk that a longer levy period simply reduces accountability and the frequency with which the ITB's approach is scrutinised. 

If an extension is considered, it should be accompanied by more robust mid-period reporting requirements and genuine mechanisms for industry to raise concerns about ITB performance between levy cycles.