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Issue 3 » January 2014 Civil Service Quarterly Legislation.gov.uk and Good Law

» Clear laws are essential to the economy and society, but people often find them difficult to understand. Recent research has been exploring how to make legislation better and present it in more effective ways, says John Sheridan, Head of Legislation at The National Archives.

It’s not news that people want legislation that is simple, Good Law ...We want... accessible and easy to comply The Good Law initiative to create with. It isn’t always possible: is an appeal to everyone legislation needs to be confidence among users interested in the making precise to have the intended that the law is for them… and publishing of law legal effect, and precision – www.gov.uk/ to come together with can be complicated. But a good-law a shared objective of lot can be done to improve making legislation work the accessibility of the law. well for the users of today That’s the aim of the Good and tomorrow. Law initiative, being led by the any UK statute. Around two Office of the Parliamentary million people do so every Good law is law that is: Counsel (OPC), a partnership month. They are the users • necessary involving everyone with a of Legislation.gov.uk. The • clear role in making, shaping and challenge now is to ensure the • coherent presenting legislation. needs of this new audience • effective The National Archives are properly understood and • accessible manages Legislation.gov. addressed, so they have a fair uk, the official home of UK chance of comprehending the legislation. We are actively legislation they are reading. bring legislation into force, involved in the Good Law The National Archives, the often contain transitional Initiative, and over the last organisation responsible for arrangements – rules that are year we have been working Legislation.gov.uk, has been intended to apply before the closely with the OPC, who working to develop a deeper new law comes fully into force. draft Government primary understanding of users’ Transitional arrangements legislation, conducting experience with the legislation are put in place for very good research that has brought the they find online. reasons, but that’s not always drafters of legislation much We know that people clear to a non-specialist reader. closer to the users, so they can struggle with legislation for And, third, legislation better understand user needs. three main reasons. isn’t easy to read, with its First, there’s a lot of it and schedules, sections, and it interconnects in ways that cross references, its legal What do users think? aren’t always straightforward language and provisions that or obvious. are divided between primary The web has transformed Second, the way legislation and secondary legislation. public access to legislation. works is complex. For example, Even lawyers struggle, and too The law is no longer in the different elements of an often people are intimidated by hands of those with access to Act can come into force at legislation. a professional library. Today, different times, and extend Legislation.gov.uk is mostly you are just a couple of clicks to different parts of the UK. used by people at work away from reading the text of Commencement Orders, which and for work purposes. 8

Domestic Abuse (Scotland) Act 2011

The Damages (Scotland) Act 2011 (Commencement, Transitional Provisions and Savings) Order 2011 Issue 3 » January 2014 Civil Service Quarterly

Changes related to the Companies

The Companies Act 2006 (Commencement No. 5, Transitional Provisions and Savings) Order 2007

Audit, Investigations and Community The Companies (Reporting Requirements in Mergers and Divisions) Regulations 2011 The Yarmouth (Isle of Wight) Harbour Revision Order 2011 The Limited Liability Partnerships (Accounts and Audit) (Application of Companies Act 2006) Regulations 2008 The Building Societies (Insolvency and Special Administration) (Amendment) Order 2010 The Companies Act 2006 (Amendment of Schedule 2) Order 2009 The European Public Limited-Liability Company (Amendment) Regulations 2009 Enterprise Act 2004. This shows the The Banking Act 2009 (Exclusion of Insurers) Order 2010 Damages (Scotland) Act 2011 The Companies Act 2006 (Transfer of Audit Working Papers to Third Countries) Regulations 2010 The Companies Act 2006 (Part 35) (Consequential Amendments, Transitional Provisions and Savings) Order 2009

The Statutory Auditors and Third Country Auditors (Amendment) Regulations 2008 The Banking Act 2009 (Bank Administration) (Modification for Application to Banks in Temporary Public Ownership) Regulations 2009 proportion of the statute book that The Insurance Accounts Directive (Miscellaneous Insurance Undertakings) Regulations 2008 The Statutory Auditors and ThirdThe Country Companies Auditors Act 2006 Regulations(Commencement 2007 No. 8, Transitional Provisions and Savings) Order 2008The Companies (Share Capital and Acquisition by Company of its Own Shares) Regulations 2009 The Insolvency (Company Arrangement or Administration Provisions for an Industrial and Provident Society) Order () 2008

The Banking Act 2009 (Bank Administration) (Modification for Application to Multiple Transfers) Regulations 2009 needs to be taken into consideration The Investment Bank (Amendment of Definition) Order 2011 The Companies Act 2006 (Substitution of Section 1201) Regulations 2009 The Companies Act 2006 (Amendment of Schedule 2) (No. 2) Order 2009 The Companies (Shareholders’ Rights) Regulations 2009 The Companies (Revision of Defective Accounts and Reports) Regulations 2008 when looking at the current in-force The Companies (Companies Authorised to Register) Regulations 2009 The Companies Act 2006 (Annual Return and Service Addresses) Regulations 2008 The Companies Act 2006 (Extension of Takeover Panel Provisions)The Companies (Isle of ActMan) 2006 Order (Allotment 2009 of Shares and Right of Pre-emption) (Amendment) Regulations 2009 state of just that one Act. The PartnershipsThe Companies (Accounts) Act 2006 Regulations (Amendment) 2008 (Accounts and Reports) Regulations 2008

The Companies Act 2006 (Accounts, Reports and Audit) Regulations 2009 The Companies Act 2006 (Annual Returns) Regulations 2011 The Insurance Accounts Directive (Lloyd’s Syndicate and Aggregate Accounts) Regulations 2008

The Bank Accounts Directive (Miscellaneous Banks) Regulations 2008 The Overseas Companies (Execution of Documents and Registration of Charges) Regulations 2009 The Companies (Mergers and Divisions of Public Companies) (Amendment) Regulations 2008

The Financial Assistance Scheme (Miscellaneous Provisions) Regulations 2008

The Companies Act 2006 (Amendment of Section 413) Regulations 2009

National Insurance Contributions Act 2008

The Companies Act 2006 (Extension of Takeover Panel Provisions) (Isle of Man) Order 2008

The Scottish and Northern Ireland Banknote Regulations 2009 The Northern Rock plc Transfer Order 2009 The Companies Act 2006 (Commencement No. 7, Transitional Provisions and Savings) Order 2008 The Water Industry (Special Administration) Rules 2009 The Statutory Auditors (Delegation of Functions etc) Order 2008 The Capital Requirements (Amendment) Regulations 2010

The Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009 The Financial Markets and Insolvency (Settlement Finality) (Amendment) Regulations 2009

The Housing (Scotland) Act 2010 (Commencement No. 2, Transitional, Transitory and Saving Provisions) Order 2011 Pensions Regulator Tribunal (Transfer of Functions) Act (Northern Ireland) 2010

The Government of Wales Act 2006 (Consequential Modifications, Transitional Provisions and Saving) Order 2009 The Occupational and Personal Pension Schemes (Automatic Enrolment) Regulations 2010

The Kaupthing Singer & Friedlander Limited Transfer of Certain Rights and Liabilities Order 2008 The Overseas Companies Regulations 2009 The European Economic Interest Grouping (Amendment) Regulations 2009

The Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) Order 2009

The Pensions Act 2007 (Abolition of Contracting-out for Defined Contribution Pension Schemes) (Consequential Amendments) (No. 2) Regulations 2011 The Companies (EEA State) Regulations 2007

The Personal Accounts Delivery Authority Winding Up Order 2010 The Companies (Registrar, Languages and Trading Disclosures) Regulations 2006 The Building Societies (Insolvency and Special Administration) OrderThe 2009 Heritable Bank plc Transfer of Certain Rights and Liabilities Order 2008 The Companies (Late Filing Penalties) and Limited Liability Partnerships (Filing Periods and Late Filing Penalties) Regulations 2008 The Amendments to Law (Resolution of Dunfermline Building Society) Order 2009 Banking Act 2009 The Regulated Covered Bonds Regulations 2008

The Education (Student Loans) (Repayment) (Amendment) Regulations (Northern Ireland) 2011

The PPP Administration OrderThe Rules Markets 2007 in Financial Instruments Directive (Consequential Amendments) Regulations 2007 Companies ActThe Northern2006 Rock plc Transfer Order 2008 The Corporation Act 2010 (Transitional Provision) Order 2010 Housing (Scotland) Act 2010 The Pensions Act 2008 (Abolition of Protected Rights) (Consequential Amendments) (No.2) Order 2011 The Education (Student Loans) (Repayment) (Amendment) Regulations 2010 Limited Liability Partnerships Act 2000 The Education (Student Loans) (Repayment) (Amendment) Regulations (Northern Ireland) 2010 Financial Services Act 2010 Co-operative and Community Benefit Societies and Credit Unions Act 2010

Savings Accounts and Health in Pregnancy Grant Act 2010

The Reinsurance Directive Regulations 2007 The Corporation Tax (Instalment Payments) (Amendment) Regulations 2011 Consumer Protection Act 1987 The Companies Act 2006 (Consequential Amendments and Transitional Provisions) Order 2011 The 2009, Schedule 35 (Special Annual Allowance Charge) (Cessation of Effect) Order 2010 The Charities Act 2008 (Transitional Provision) Order (Northern Ireland) 2011 National Insurance Contributions Act 2011 The Statutory Auditors and Third Country Auditors (Amendment) Regulations 2011 The Special Annual Allowance Charge (Variation of Rate) Order 2010 The Companies Acts (Unregistered Companies) Regulations 2007 Pensions Act 2007

The Income Tax (Pay As You Earn) (Amendment No. 2) Regulations 2009 The Qualifying Oil Fields Order 2010 The Bradford & Bingley plc Transfer of Securities and Property etc. Order 2008 The Unregistered Companies Regulations 2009 The Prospectus Regulations 2005 The Transfer of Functions (Dormant Accounts) Order 2010 Insolvency Act 1986

The Companies Act 2006 (Commencement No. 2, Consequential Amendments, Transitional Provisions and Savings) Order 2007 The Education (Student Loans) (Repayment) (Amendment) Regulations 2011 The Goods (Holding, Movement and Duty Point) Regulations 2010

Financial ServicesCompany and Markets Directors Act 2000 Disqualification Act 1986 Companies Act 1985

The Social Security (Contributions) (Amendment No. 4) Regulations 2010

Pensions Act 2008 Dormant Bank and Building Society Accounts Act 2008

Property Misdescriptions Act 1991 The Companies (Cross-Border Mergers) Regulations 2007 The Electronic Money Regulations 2011 Pensions Act 1995

The Special Annual Allowance Charge (Protected Pension Input Amounts) Order 2010 Restrictive Practices Court Act 1976 Industrial and Provident Societies Act 1965 The Social Security (Contributions) (Amendment No. 4) Regulations 2009 The Transfer of Functions (Equality) Order 2010 Bankruptcy (Scotland) Act 1985 Companies Consolidation (Consequential Provisions) Act 1985

The Investment Bank Special Administration Regulations 2011

Prices Act 1974 The Community Interest Company (Amendment) Regulations 2009 The Channel Tunnel (Alcoholic Liquor and Tobacco Products) Order 2010

Finance Act 2008 Bank of England Act 1998 Insolvency Act 1985 The Corporation Tax Act 2010 (Amendment) Order 2010 The Banking Act 2009 (Parts 2 and 3 Consequential Amendments) Order 2009 The Income Tax (Construction Industry Scheme) (Amendment) Regulations 2009 CompaniesCompanies (Audit,Act 1989 Investigations and Community Enterprise) Act 2004 Corporation Tax SocialAct Security (Consequential2010 Provisions) Act 1992 The Charities and Trustee Investment (Scotland) Act 2005 (Consequential Provisions and Modifications) Order 2006 The Education (Student Loans) (Repayment) Regulations 2009 The Government of Wales Act 2006 (Consequential Modifications and Transitional Provisions) Order 2007 Friendly SocietiesThe CompaniesAct 1992 (Audit, Investigations and Community Enterprise) (Northern Ireland) Order 2005 Consolidated Fund (No. 2) Act 2002 Charities Act (Northern Ireland) 2008

The Transfer of Tribunal Functions Order 2010 The Charities (Pre-consolidation Amendments) Order 2011 The Finance Act 2009, Schedules 55 and 56 (Income Tax Self Assessment and Pension Schemes) (Appointed Days and Consequential and Savings Provisions) Order 2011 The Education (Student Loans) (Repayment) Regulations (Northern Ireland) 2009 Flood and Water Management Act 2010 Finance (No. 2) Act 2010 Finance Act 1994 Welfare Reform Act 2009

Finance (No. 3) Act 2010 Consumer Credit Act 1974 Income and Corporation Act 1988 The Companies Act 2006 (Commencement No. 3, Consequential Amendments, Transitional Provisions and Savings) Order 2007 Water Act 1989 The Finance Act 2009, Schedule 47 (Consequential Amendments) Order 2009 Water Consolidation (Consequential Provisions) Act 1991

The Enactment of Extra-Statutory Concessions Order 2011 Taxation (International and Other Provisions) Act Broadcasting2010 Act 1996 Budget Responsibility and National Audit Act 2011 Anti-terrorism, Crime and Security Act 2001

Postal Services Act 2011 The Community Infrastructure Levy Regulations 2010 The Offshore Funds (Tax) Regulations 2009 The Companies Act 2006 (Consequential Amendments, Transitional ProvisionsCriminal Justice and and Savings) Police Act 2001 Order 2009 Finance Act 1996 Youth Justice and Criminal Evidence Act 1999 Coal industry Act 1994 The Companies Act 2006 (Consequential Amendments etc) Order 2008 Deregulation and Contracting Out Act 1994

Housing Act 1996 Transport Act 2000 Northern Ireland Assembly Disqualification Act 1975 Charities Act 2006 The Taxation (International and Other Provisions) Act 2010 (Amendment) Order 2010 The Transfer of TribunalValue Added Functions Tax Act 1994 and Revenue and Customs Appeals Order 2009 The Authorised Investment Funds (Tax) (Amendment) Regulations 2009 Gas Act 1986 IdentityThe Documents Housing andAct 2010Regeneration Act 2008 (Consequential Provisions) Order 2008 The Finance Act 2010, Section 23 and Schedule 2 (High Income Excess Relief Charge) (Repeal) Order 2010 Terrorism Act 2000 Postal Services Act 2000

The Consumer ProtectionHousing from Unfair and Trading Regeneration Regulations 2008 Act 2008 Corporation Tax ActFinance Act 1991 2009 Enterprise Act 2002 Scotland Act 1998 The Northern Ireland Act 1998 (Devolution of Policing and Justice Functions) Order 2010 The Corporation Tax Act 2009 (Amendment) Order 2009 The Charities Act 2006 (Changes in Exempt Charities) Order 2011 The (Penalties for Errors and Failure to Notify etc) (Consequential Amendments) Order 2010 Airports Act 1986 Competition Act 1998 European Communities Act 1972 The Environmental Permitting (England and Wales) Regulations 2010 House of Commons DisqualificationElectricity Act 1975 Act 1989 Administration of Justice Act 1985 Regulation of Investigatory Powers Act 2000

The Corporation Tax Act 2009 (Amendment) Order 2010 The Northern Rock plc (Tax Consequences) Regulations 2009 The Housing and Regeneration Act 2008 (Registration of Local Authorities) Order 2010 Policing and CrimeMagistrates’ Act 2009 Courts Act 1980

Greater London Authority Act 1999 Competition Act 1980 Employment Rights Act 1996 Water Resources Act 1991 The Equality Act (Sexual Orientation) Regulations 2007 Railways Act 1993 The Mutual Societies (Transfers of Business) (Tax) Regulations 2009 Coroners and Justice Act 2009

The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) (Amendment) Regulations 2009 Northern Ireland Act 2009 Tribunals and Inquiries Act 1992 Insolvency Act 2000 The Corporation Tax (Implementation of the Mergers Directive) RegulationsThe Finance2011 Act 2009, Section 96 and Schedule 48 (Appointed Day, Savings and Consequential Amendments) Order 2009 Legal Services Act 2007 Civil Aviation Act 1982 The Transfer of Tribunal Functions (Lands Tribunal and Miscellaneous Amendments)Parliamentary Order Commissioner2009 Act 1967 Broadcasting Act 1990 Courts and Legal Services Act 1990 Water Industry Act 1991

The Alternative Finance Arrangements (Amendment) Order 2009 Crime and Security Act 2010 Data Protection Act 1998 Planning Act 2008 Planning Act (Northern-Ireland) 2011 Department of Justice Act (Northern Ireland) 2010 Fair Trading Act 1973 The Transfer of Functions (Media and Telecommunications etc.) Order 2011

The Offshore Funds (Tax) (Amendment) Regulations 2011 Local Democracy, Economic Development and Construction Act 2009 Bribery Act 2010 The Transfer of Functions (Equality) Order 2007 The Transfer of Functions of the Charity Tribunal Order 2009 Copyright, Designs and Patents Act 1988 Superannuation Act 1972 Marine and Coastal Access Act 2009 Criminal Justice Act 1988 Police Act 1997

The Apprenticeships, Skills, Children and Learning Act 2009 (Consequential Amendments) (England and Wales) Order 2010 The Corporation Tax (Land Remediation Relief) Order 2009 Estate Agents Act 1979

The Secretary of State for Business, Innovation and Skills Order 2009 Chiropractors Act 1994 The Northern Ireland Court Service (Abolition and Transfer of Functions) Order (Northern Ireland) 2010 Trade Descriptions Act 1968 Osteopaths Act 1993 Weights and Measures Act 1985 Criminal Justice and Immigration Act 2008 The Legal Services Act 2007 (Functions of a Designated Regulator) Order 2008 Patents Act 1977 Local Government Act 1972 The Local Education Authorities and Children's Services Authorities (Integration of Functions) Order 2010

Telecommunications Act 1984 The Equality Act 2010 (Consequential Amendments, Saving and Supplementary Provisions) Order 2010 Dentists Act 1984 Utilities Act 2000

Criminal Justice and Licensing (Scotland) Act 2010

The Overhead Lines (Exempt Installations) Order 2010

Channel Tunnel Rail Link Act 1996

The Legal Services Act 2007 (Designation as a Licensing Authority) Order 2011 Civil Evidence Act 1968 The Infrastructure Planning (Miscellaneous Prescribed Provisions) Regulations 2010 The Legal Services Act 2007 (Commencement No. 6, Transitory, Transitional and Saving Provisions) Order 2009

Apprenticeships, Skills, Children and Learning Act 2009 Children, Schools and Families Act 2010 Education and Skills Act 2008 The Conservation of Habitats and Species Regulations 2010

Justices of the Peace Act 1997 The Legal Services Act 2007 (Transitory Provision) Order 2008 Law Reform (Miscellaneous Provisions) (Scotland) Act 1968 The Health Care and Associated Professions (Miscellaneous Amendments and Practitioner Psychologists) Order 2009

Timeshare Act 1992

Children and Families (Wales) Measure 2010

The Legal Services Act 2007 (Appeals from Licensing Authority Decisions) Order 2011 The Marine and Coastal Access Act 2009 (Amendment) Regulations 2011

The Electronic Communications and Wireless Telegraphy Regulations 2011

The Legal Services Act 2007 (Approved Regulators) Order 2009 The Legal Services Act 2007 (Functions of an Approved Regulator) Order 2009 The Marine (Scotland) Act 2010 (Consequential Provisions) Order 2010

The Legal Services Act 2007 (Commencement No.1 and Transitory Provisions) Order 2008

The Legal Services Act 2007 (Transitional, Savings and Consequential Provisions) (Scotland) Order 2008

Children and Young Persons Act 2008

Academies Act 2010

Double Jeopardy (Scotland) Act 2011

Local Government (Wales) Measure 2011

The Greater Manchester Combined Authority Order 2011 The Remand on Bail (Disapplication of Credit Period) Rules 2008

The Health and Social Care Act 2008 (Consequential Amendments No.2) Order 2010

The Local Education Authorities and Children’s Services Authorities (Integration of Functions) (Wales) Order 2010 The Education and Skills Act 2008 (Commencement No. 4, Commencement No. 3 (Amendment), Transitory and Saving Provisions) Order 2009 The Charities Act 2006 (Principal Regulators of Exempt Charities) Regulations 2011 The Education (Pupil Referral Units) (Application of Enactments) (England) (Amendment) Regulations 2010 The Education and Skills Act 2008 (Commencement No. 7 and Transitory Provisions) Order 2010 9

Issue 3 » January 2014 Civil Service Quarterly Legislation.gov.uk and good law

The majority of users are not lawyers and therefore The Open Government Partnership UK lack access to one of the National Action Plan 2013 to 2015 commercial subscription Commitment ten in the action plan states that the UK services. They are drawn from a much wider group of people Government will: who need to know, cite or use • promptly publish all new primary and secondary legislation legislation as part of their job. on Legislation.gov.uk For example, imagine • bring the revised versions of primary legislation on someone in the human Legislation.gov.uk up to date by the end of 2015 and keep resources department of a them up to date subsequently mid-size company, trying to • make legislative data available in an open and accessible understand the impact of the format to allow people to re-use content under the terms of Pensions Act 2011 on their the UK’s Open Government Licence business. Of course they will read the guidance, but they also want to check the text of Legislation.gov.uk has been available' version that shows the legislation itself. That’s a carefully designed to present how the legislation is now is very typical Legislation.gov.uk user. legislation on the web so that important. the content and status of each For advanced users there is piece of legislation is clear a timeline which can be turned Legislation.gov.uk and accessible. on to see how the legislation The website has been has changed. Our regular surveys and studies designed to provide additional Other advanced features have given us a great insight into information without cluttering include a display of the territorial the needs of these non-legally the user interface for more extent of the legislation, showing trained users of legislation. experienced users. This has where in the UK it is the law. Most people assume, when been done through the status You can also search based on they access legislation, that it is bar which expands to list any a particular territorial extent or current, in force and applies to unapplied effects and contextual search how legislation stood at a where they live – which may not help buttons across the given point in time. be the case. As a consequence, screen. Giving people a 'latest The precise way legislation is named on Legislation.gov. uk also means that people can now cite legislation much more accurately on the wider web. This phenomenon is most apparent on Twitter, where increasingly people use an exact Legislation.gov.uk citation rather than a vague reference to the legislation document when they want to talk about it.

Bringing together drafters and users of legislation

The Good Law initiative has provided an opportunity for The National Archives to work much more closely with the OPC. An example is the new research we recently conducted together

Version control on Legislation.gov.uk showing to explore how different how legislation has changed over time. drafting styles and 10

Issue 3 » January 2014 Civil Service Quarterly

different approaches to on legislation.gov.uk, to ensure presentation can aid or improve Updating the statute book quality and accuracy. comprehension. The expert participation Taking the principle of All users of legislation want the programme has already starting with users’ needs, legislation they access from an substantially increased not Government needs, we official source to be up to date. the resources available to investigated possible options The challenge is that Parliament update legislation, and new and strategies for improving passes legislation that makes, editorial processes and tools legislation. Thousands of users on average, around 15,000 have introduced significant of Legislation.gov.uk took part changes to other pieces of efficiencies. The National Archives in an online study, telephone legislation a year. It is a massive is working to bring all primary interviews and one-to-one lab task just to keep up. legislation on Legislation.gov.uk testing. It was the first time To bring the revised up to date by the end of 2015. research of this type has been legislation on Legislation.gov. The sheer volume of undertaken by the Government, uk up to date, The National legislation, its piecemeal trying to discover which Archives has an 'expert structure, its level of detail and ways of drafting legislation, participation programme', frequent amendments can seem and presenting it, best help sharing responsibility for overwhelming. But difficulties people comprehend the law. curating and managing the with understanding the law Participants were shown a Government’s legislation are not inevitable. Getting to short provision drafted in one database with others, inside grips with new users’ needs style, then shown alternative and outside Government. and working collaboratively versions of the provision We have also developed new with those that have a shared drafted in different styles and editorial tools that streamline responsibility for promoting and asked to express a preference and automate our processes delivering good law is already for one style. Users were also of updating legislation as leading to real change, with shown sections of legislation much as possible, as well as much more to come. and asked simple questions to allowing expert participants check if their understanding of to work remotely. Everyone’s You can find out more about it accurately reflected the law. work is double checked by the Good Law initiative at: Findings showed that people reviewers before it is published www.gov.uk/good-law can really struggle to find their way around legislation. Many do not understand common terms such as 'commencement' or 'prescribed', or were puzzled by cross-references such as references to 'subsection (1)' or 'Schedule x makes provision about...'. These really practical insights have been invaluable. We now know much better what the difficulties are. We are using the findings to develop new ways of presenting legislation on Legislation.gov.uk, as well as developing better support materials to help users find their feet. This work is also impacting on drafting practice. The OPC now have evidence to evolve their guidance for the drafters of legislation and have been working through the findings in detail.