The First‑tier Tribunal has partly upheld an appeal against a decision of the Information Commissioner concerning the disclosure of reports produced by the Home Office’s Extremism Analysis Unit but largely endorsed the Home Office’s approach, ruling that while most of the requested information was lawfully withheld on national security grounds, certain report titles should not have been exempt.
The appellant, Edward Williams, made a Freedom of Information Act (FOIA) request to the Home Office in June 2024 seeking the titles of all reports produced by the Extremism Analysis Unit (EAU), listed chronologically; and copies of all such reports, excluding personal data where there was no legitimate interest in disclosure.
The Home Office confirmed that it held the information but refused disclosure in full, relying on a range of exemptions including sections 24 (national security), 27 (international relations), 31 (law enforcement), 35 (formulation of government policy), 38 (health and safety) and 40 (personal data).
Following an internal review and a complaint to the Information Commissioner, the Commissioner concluded in August 2025 that section 24 was engaged and that the public interest favoured maintaining the exemption. Mr Williams appealed that decision to the Tribunal.
On appeal (Edward Williams v Information Commissioner & Anor [2026] UKFTT 568 (GRC)), the Tribunal was asked to determine whether section 24 FOIA was engaged by the withheld information; and if so, whether the public interest in maintaining the exemption outweighed the public interest in disclosure.
The Home Office was joined as a second respondent and relied on both open and closed evidence, including witness evidence from a senior civil servant responsible for counter‑extremism analysis.
The Tribunal accepted the Commissioner’s concession that the titles of 26 EAU reports disclosed to Mr Williams in March 2019 should not have been withheld. It therefore allowed the appeal to that limited extent and issued a substituted decision notice confirming that no FOIA exemption applied to those titles. As they had already been disclosed, no further action was required.
However, in relation to the remaining report titles and the contents of all reports, the Tribunal found that the Home Office was entitled to rely on the national security exemption under section 24 of the Freedom of Information Act 2000. Having reviewed both the open and closed evidence, it accepted the Home Office’s position that disclosure of the full list of titles – and a fortiori the reports themselves – would reveal the scope, focus and potential gaps in the Home Office’s extremism intelligence capability over time.
The Tribunal accepted evidence that such information could be exploited by extremist actors, even where individual reports were historical in nature, and that the passage of time did not materially reduce the risk to national security.
Mr Williams argued that partial or redacted disclosure should have been considered. The Tribunal rejected this, concluding that redacting all information necessary to mitigate the national security risk would leave material that was meaningless and did not advance the aims of transparency or accountability.
In carrying out the public interest balancing exercise, the Tribunal recognised the significant public interest in openness, particularly in relation to counter‑extremism policy and the use of public funds. However, it held that this was outweighed by the strong and enduring public interest in safeguarding national security, especially given the nature of extremism and the potential consequences of disclosure.
