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Agentic flooding: is your council ready for AI-written requests?

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If you work in a council planning, FOI or complaints team, you may have noticed it already: the letters are getting longer, more legal-sounding and more frequent.

In August The Economist put the problem on its cover. Its leader, 'How AI is breaking the British state', argues that citizens using AI to file objections, appeals and claims will 'overwhelm bureaucracies built for the age of the post and the telephone'. It reports that the backlog in employment tribunals has risen by 55% in a year, in large part due to AI-fuelled claims, and that demand for emergency injunctions has surged 100-fold. On planning it is blunt: a regime 'paralysed by AI objections' risks getting nothing built at all.

That's the headline. The evidence underneath it is now available too.

From anecdote to evidence

A new paper co-authored by the Oxford-based Centre for the Governance of AI (GovAI) gives the problem its name: agentic flooding of government services. They define it as a surge in the volume or complexity of requests, caused by AI, that substantially strains a public service.

They screened 2,288 candidate services and identified 84 cases across 11 jurisdictions and 13 service domains. In 69% the government body itself blamed AI, and in 87% the mechanism was LLM-written text.

Bar chart of the 84 cases. Longer, more complex submissions 90%; more submissions 60%; both 50%

Some of the examples are striking. German social courts largely attribute a 55% year-on-year rise in caseload in 2025 to AI-generated claims, with some submissions running past 4,000 pages. Australia has considered bringing back FOI fees in response to a wave of AI-written requests. Closer to home, UK cases include Local Plan consultations, Money Claims Online and Housing Ombudsman complaints.

Annualised submission volumes 2018 to 2025 for 12 government services, including UK Housing Ombudsman, Financial Ombudsman and Solicitor's Conduct complaints
Submission volumes for 12 services, 2018 to 2025. The dashed line marks the release of ChatGPT; red means officials asserted AI involvement, blue means secondary sources did. Taken from: Schmitz, Hammond and Chan (2026), CC BY 4.0

The authors are careful to say their method doesn't support causal or quantitative claims; only 25 of the cases have time-series data at all. But when dozens of independent bodies in different countries point at the same cause, it's worth paying attention.

Why councils are exposed

The paper's risk matrix scores 13 factors: five that make a flood more likely and eight that make it more severe. The authors rate risk highest for financially attractive services where complex paperwork has historically held demand down, such as court claims and tax returns.

Most council services are less lucrative than a tax rebate, but stopping an unwanted development next door is a strong incentive in its own right. And several council services score badly on the factors that decide whether a flood can be absorbed:

Risk factor in the paperWhat it looks like in a council
Susceptible service interfaceConsultation portals, FOI inboxes, complaint forms and objection letters accept text of almost any length
Effort required to submit, and the gap between assumed and full take-upWriting a coherent objection or formal complaint used to take time and know-how, which quietly capped volumes. An LLM removes that in seconds
Processing effort mandated by lawStatutory response times, consultation duties and the right to a reasoned answer mean the pile can't be skimmed
Risk matrix of 13 factors predicting the likelihood and severity of agentic flooding, with public comment procedures in the high-likelihood corner
The paper's risk matrix. Note where public comment procedures sit. Taken from: Schmitz, Hammond and Chan (2026), CC BY 4.0

Add budgets that assume historic take-up and teams already running close to capacity, and the headroom disappears quickly.

In principle this is a good thing. The Economist calls it 'a cracking result for fed-up citizens': the poor could exercise their rights as successfully as the sharp-elbowed middle classes do today. The problem is the processing side, which hasn't changed. And it will get harder. Officials complain about AI 'slop' today, but as models improve they will face 'demands as well-crafted as a first-class lawyer's'. Filtering out the weak submissions won't be enough.

The quick fix has a cost

The paper sorts government responses into two strategies. One suppresses demand, by adding friction or reducing the benefit of applying. The other increases capacity, by adding staff, redesigning the service or using AI in processing.

Governments responded in just over half of the cases. Friction measures (fees, rate limits, identity checks, IP blocking) appeared in 17%. Japanese authorities blocked consultation submissions by IP address, and some bodies batch-dismissed responses.

The Economist leans the same way. It proposes pruning procedural rights, charging for FOI requests 'as other countries do', bringing fees to employment tribunals and creating fewer entitlements that are 'ripe for AI-fuelled claims'.

These measures work, and they're quick. But they hit poorer, less digitally confident and more vulnerable residents hardest, and they throw away the accessibility gains AI offers. Capacity building avoids that trade-off but needs lead time, which is why the authors want work to start before a surge, not during one.

Table of government responses to agentic flooding, grouped into suppress demand and increase capacity
Two strategies: suppress demand, or increase capacity. Taken from: Schmitz, Hammond and Chan (2026), CC BY 4.0

Interestingly, The Economist ends up in the same place. It calls the most important task 'remaking the state with AI', including a planning system that could check for itself whether a housing development meets the zoning code. We'd keep the decision with officers. But building processing capacity before the surge is the right direction, and that's where we can help.

Meeting AI-written requests with well-governed AI

In a quarter of the paper's cases (21 of 84), governments introduced AI tools in response, more often than they added friction. One is a UK planning case: for Local Plan consultations, officials brought in AI to analyse sentiment across large numbers of public comments. Bounded tools like this, handling one step with a human in the loop, are the sensible place to start.

Bar chart of government responses across 84 cases. Introduced AI tools 25%; added friction 17%; redesigned the service 15%

We've been building exactly these kinds of pipelines, and they're already in use:

CapabilityWhat we've builtCouncil use
Planning document intelligenceAround 700 spatial planning documents for a group of Dutch municipalities, indexed page by page. Search by meaning, place names resolved to geometry, maps inside PDFs searchable, zoning by address, all queryable by AI assistants through MCPLink every consultation response to the site or policy it concerns
Semantic searchSemantic FME Insights turns thousands of files into a plain-English searchable index, re-indexing incrementally as new material arrivesGroup near-duplicate and templated submissions; find precedent
Document extractionLabs apps using computer vision and generative AI to pull tables from PDF reports into structured dataTurn long attachments into structured, reviewable data

Point the same pattern at a consultation inbox and the picture changes. Every response is read, tagged by theme and sentiment, and linked to the site or policy it's about. Templated submissions are grouped, and the distinct, well-argued points are pulled out rather than lost in the volume. Officers start from a map and a ranked summary, not a 4,000-page letter.

Two principles we hold to, given the public-sector context:

PrincipleWhat it means
No black boxWe hand over the workflows with documentation and mentor your team to run and change them
Your data stays yoursRuns on Gemini, OpenAI or a local LLM in your own infrastructure, with no external API calls if needed

Three things councils can do now

The paper makes three recommendations that don't depend on predicting how fast AI moves. We'd frame them for councils like this:

ActionWhat it involvesWhy it matters
Audit your exposureScore services on free-text input, suppressed demand, statutory processing duties and budget headroomA short list of services to prepare first. We can run this with your team
Strengthen the front doorIdentity verification and structured forms, pre-filled with data you already holdMakes per-person rate limits enforceable and industrial-scale submissions harder, without penalising genuine residents
Get clarity on what's lawfulReview fees, channel restrictions and AI-assisted processing against administrative and AI lawRemoves a barrier to acting early

The question worth asking

If your next Local Plan consultation drew five times the usual responses, many of them long and AI-written, would your team still meet its statutory deadlines without closing the door on residents?

If not, you're far from alone. But the time to build that capacity is before the surge, not during it.

References

  1. Schmitz, C., Hammond, L. and Chan, A. (2026). Characterizing Agentic Flooding of Government Services. To appear in Proceedings of the 9th AAAI/ACM Conference on AI, Ethics and Society (AIES). arXiv:2608.16603. Dataset
  2. The Economist (2026). How AI is breaking the British state. Leader, 6 August 2026.
  3. Avineon Tensing: Semantic FME Insights
  4. Avineon Tensing: FME Labs
  5. Avineon Tensing: G-Cloud 15 services for the public sector

Get in touch with us

To talk about preparing your council's services for AI-driven demand.

CTAE Oliver Morris