Control Routine Waivers, Discounts, and Exceptions

Require every waiver, discount, or special treatment to be grounded in a written rule and recorded against the account. Many licensing systems lose revenue not because the schedule is weak, but because informal exceptions become normal practice over time. Tightening exception control can restore fairness quickly without changing headline rates.

• Staff or politicians frequently grant special treatment but the basis is not clear.

• It is difficult to explain why similar firms pay very different amounts.

• Revenue leakage appears to be concentrated in exemptions or negotiated reductions.

The city should clarify which exceptions are allowed under law and who can approve them. Where needed, a short administrative order can restrict approval to a small number of authorised officers.

Maintain an exception register, require written justification and supporting documents, and review waived amounts monthly so management can see patterns early.

• Leadership is unwilling to constrain discretionary relief because it is being used as an informal policy or patronage tool.

This is often less about technical reform and more about whether the city is ready to reduce informal discretion.

Require every waiver, discount, or special treatment to be grounded in a written rule and recorded against the account. Many licensing systems lose revenue not because the schedule is weak, but because informal exceptions become normal practice over time. Tightening exception control can restore fairness quickly without changing headline rates.

• List every formal waiver, discount, exception, and special treatment currently allowed and then compare that list with what is happening in practice.

• Limit approval authority to a small number of named officers and require a written reason plus supporting evidence for each exception.

• Create an exception register linked to the account so management can see total waived amounts by sector, ward, and approving officer.

• Review the register monthly and reverse any unsupported exceptions before they become accepted custom.

The city should clarify which exceptions are allowed under law and who can approve them. Where needed, a short administrative order can restrict approval to a small number of authorised officers.

Maintain an exception register, require written justification and supporting documents, and review waived amounts monthly so management can see patterns early.

• Staff or politicians frequently grant special treatment but the basis is not clear.

• It is difficult to explain why similar firms pay very different amounts.

• Revenue leakage appears to be concentrated in exemptions or negotiated reductions.

• Leadership is unwilling to constrain discretionary relief because it is being used as an informal policy or patronage tool.

• The city cannot yet prove the charging basis well enough to defend corrections and explain them clearly to affected users.

• The main operational risk is uneven treatment. Similar businesses should not be reclassified differently because different officers handle them.

• Where politically connected firms are part of the problem, start with sectors where the legal evidence is strongest and the public case is easiest to defend.

• This is often less about technical reform and more about whether the city is ready to reduce informal discretion.