FOI Appeal Builder — Request an Internal Review After a Refusal

A refusal is the beginning of an FOI, not the end of it. Internal reviews overturn a meaningful share of refusals, and the ones that succeed usually attack the application of the exemption rather than restating the original request.

Last reviewed: 24 August 2026Next review due: 24 August 2027

FOI Appeal Builder

Generate an internal review request after a Freedom of Information refusal. An internal review is normally expected before you complain to the Information Commissioner's Office (ICO), though section 50(2)(a) makes that the Commissioner's discretion rather than a bar. Fill in the details and copy or print the letter.

Authority name

Original request date

Refusal date

Exemption section cited by authority

Authority claims the request would cost over £600 (central government) or £450 (other public bodies) to process. Check if the request can be narrowed to bring it within the cost limit.

Why you dispute the refusal

Generated internal review letter



[Authority Name]

Dear Sir/Madam,

Request for Internal Review – Freedom of Information Act 2000

I am writing to request an internal review of your decision to refuse my Freedom of Information request, submitted on [date] and refused by letter dated [date].

EXEMPTION CITED

Your refusal relied on s.12 – Cost limit of the Freedom of Information Act 2000.

GROUNDS FOR REVIEW

I dispute the application of this exemption for the following reasons:

[Set out your reasons for disputing the refusal — e.g. the public interest in disclosure outweighs any prejudice; the information is not genuinely exempt; the cost estimate is inflated; or the exemption has been misapplied]

I therefore request that [Authority Name] conduct a formal internal review of this decision. I ask that you consider:

1. Whether the provision relied on has been correctly identified and applied;
2. Where a qualified exemption under Part II is relied on, whether the public interest test has been conducted properly and in good faith. (Sections 12 and 14 are not Part II exemptions and carry no public interest test; if one of those was relied on, please address instead whether the estimate or the vexatiousness finding was reasonable.);
3. Whether partial disclosure or anonymisation would allow some information to be released.

TIMESCALE

I note that the ICO expects public authorities to complete internal reviews within 20 working days (40 in exceptional cases). Please confirm receipt of this review request and provide a response accordingly.

If your review upholds the original refusal, please set out your full reasoning in writing so that I may consider whether to refer this matter to the Information Commissioner under section 50 of the Freedom of Information Act 2000.

Yours faithfully,

[Your Name]
[Your Email Address]
[Your Publication / Organisation, if applicable]

Next step: If the internal review upholds the refusal, you have the right to complain to the Information Commissioner's Office under section 50 of FOIA. Use the ICO Complaint Builder tool to draft your complaint.

How it works

Five inputs: authority name, the date you sent the original request, the date of the refusal, the exemption cited from a list of eight (s.12 cost limit, s.14(1) vexatious, s.21 already available, s.22 future publication, s.31 law enforcement, s.40 personal data, s.41 confidentiality, s.43 commercial interests), and free text on why you dispute it.
Selecting an exemption shows a short explainer with the standard line of challenge — narrowing the request for s.12, demanding a direct link for s.21, pressing for anonymisation or aggregation for s.40, arguing for time-limited or partial disclosure for s.43.
It assembles an internal review letter naming both dates and the exemption, inserting your grounds, and putting three numbered questions to the reviewer: whether the exemption was correctly identified and applied; whether the public interest test was carried out properly and in good faith, with a built-in note that sections 12 and 14 are not Part II exemptions and carry no public interest test, redirecting the question to whether the cost estimate or the vexatiousness finding was reasonable when either of those is what you picked; and whether partial disclosure or anonymisation would let some information out.
The description above the form already states that an internal review is normally expected before a complaint to the ICO, but that section 50(2)(a) makes this the Commissioner’s discretion rather than a statutory bar. A timescale paragraph in the letter itself notes the ICO expectation of 20 working days for an internal review (40 in exceptional cases) and asks for full written reasoning if the refusal is upheld, so that you can refer the matter to the Information Commissioner under section 50.
Copy and print buttons, plus a pointer to the ICO Complaint Builder as the next step.

When to use it

Immediately after a refusal, while the reasoning in the refusal notice is still in front of you.
When an authority has claimed a qualified exemption without showing any public interest balancing.
When a section 12 cost refusal looks inflated and you want the estimate itself examined.
To create the paper trail the ICO will expect to see before it will take a complaint.

What it does not do

The eight exemptions offered are the common ones, not the full set. Refusals under s.35 policy formulation, s.36 prejudice to public affairs, s.38 health and safety, s.42 legal privilege, s.44 statutory prohibition or s.14(2) repeat requests are not in the list and you will have to edit the letter by hand.
The template is written for an outright refusal. There is no wording for a partial disclosure, an over-redacted response, a neither confirm nor deny, or the most common failure of all — no response at all inside 20 working days — despite the tools feed advertising partial disclosure.
Both dates are typed in, not calculated or checked. The tool will not tell you whether the refusal was in time, or whether you are still inside a sensible window to seek a review.

More tools

This is one of the free tools on UK JournoHub. See the full tools index for the rest.

Primary sources

FOIA 2000 s.50 — application for a decision by the Commissioner— legislation.gov.uk
FOIA 2000 s.12 — cost of compliance— legislation.gov.uk