Rateable Advertising: From hunch to half a million (in weeks)


The problem

Like other Councils, Westminster remains under significant pressure to ensure no stone is left unturned when it comes to sources of funding. 

The hunch

A hunch to explore rateable bus shelter rateable advertising was developed by the Council’s Head of Smart City following a discussion with a potential advertiser who was unaware of the relationship between digital bus shelter advertising and the process to collect business rates. 

Exploring the hunch 

They decided to act on the hunch, by using Google Street View to count the number of bus shelters on Victoria Street that had advertising. The next step involved checking the national non-domestic rates (NNDR) database to verify how many were listed. The result was that only 45% of bus shelters were listed on the database. This initial exercise identified approximately £100k of missing rateable advertising associated with 10 bus shelters. 

The next step was to size the total potential gap. This was achieved by identifying that 46% of the total number of bus shelters in Westminster were not listed as rateable properties. 

The hypothesis

The hunch therefore became a genuine hypothesis that there could be a significant gap in actual versus potential business rates income from bus shelter advertising. 

The Head of Smart City believed this to be an ideal hypothesis to be tested by the product team responsible for the Council’s camera/AI-based monitoring product line.  

Testing the hypothesis

The product team carried out an initial experiment to test the feasibility of identifying bus shelter advertising using off-the-shelf AI LLM (Artificial Intelligence Large Language Models) and this proved successful. Nevertheless, there was no immediate solution available for capturing the images of the bus shelters. So, the team recommended a faster, lower cost way to test the hypothesis and quantify the problem that involved no technology development. 

The initial activity involved several days of effort from Westminster’s data team to provide a clean list of bus shelters that were not listed in the NNDR database. 

The steps included:

  • Compiling TfL (Transport for London) bus shelter data from the Council’s geodatabase 
  • Extracting advertising records from the National Non-Domestic Rates (NNDR) database
  • Performing a range of processes including cleaning, matching, joining and updating data records

*This is a high-level summary only. There were numerous sub-steps undertaken, which the Council would be happy to share with other local authorities.

The data exercise provided the product team with 260 bus shelters not listed as rateable properties to be investigated. 

The team considered Google Street View to be the fastest and lowest cost way to survey the bus shelters. The first step involved checking with the revenue and benefits department that the age of Google Street View images should be acceptable to the Valuation Office Agency. 

In terms of the survey, the product team considered developing an AI-enabled app to automatically scan Google Street View, but having manually tested some streets, the team decided that a manual survey would be faster than developing, testing and deploying the app. 

The analysis required approximately 8 days of effort and led to the identification of 49 unlisted bus shelters with advertising from the 260 provided. The data along with supporting images was promptly provided to the revenue and benefits department for submission to the Valuation Office Agency.  

Learnings

Key learnings include:

  • It’s often good to at least invest a little time and effort in exploring a hunch. In this case, the Smart City team estimates it has provided the means for the Council to recover over half a million pounds of annual rateable value to the benefit of the public purse
  • Always pause to consider the different options to test a hypothesis as there might be a faster and lower cost option than the one that first comes to mind
  • The revenue and benefits team considered the manual survey to be an acceptable solution for them going forward to identify bus shelter and potentially other forms of rateable street advertising. The Council considers this minimum viable product (MVP) to be a great example of the product mindset in action in the Council 

Looking forward

The product team has reflected on the potential opportunity across all London councils. In Westminster, 16% of bus shelters were carrying advertising but were not listed. With over 12,000 bus shelters across London, this could represent a gap of 1,920 rateable bus shelters. Property values vary, but based on an average value of £5,000, this could equate to a potential rateable value gap of £10m across London. 

Given the above, the product team has commenced development of an app aimed at not only automating the manual process for Westminster but for others. The team is also carrying out an initial investigation into other forms of digital street advertising such as telephone boxes. 

If as a local authority, you would be interested in learning more or perhaps benefiting from the new solution, please contact smart@westminster.gov.uk.  

Tech Example

Paul Seaborn
22 September 2025 ·

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