White Paper or White Flag? And the Big Red Lines

Steve Gummer shares his insight into what Defra's new 'New Vision for Water' and the test for deliverability actually mean for the water sector in England. 

PART A – THOUGHTS FOR INDUSTRY

What’s happening?

A New Vision for Water (CP 1490), published in January 2026, sets out a once-in-a-generation reform agenda for England’s water sector. It responds to the Independent Water Commission’s “Cunliffe Review”, which in July 2025 made 88 recommendations to “reset” regulation and restore trust. The White Paper adopts many of these, outlining major changes in regulation, planning, competition, financing, and environmental oversight. Key proposals include:

• New Integrated Water Regulator: Abolish Ofwat and establish a single powerful regulator combining economic, drinking water quality and environmental functions. This body would embed a Chief Engineer to lead hands-on infrastructure inspections and house dedicated supervisory teams for each company. Stronger powers (e.g. “no-notice” inspections) will enable proactive enforcement. A Water Ombudsman will be created with legally binding powers to resolve customer complaints, aligning water with utilities like energy.
• Strategic Planning Overhaul: The myriad of 20+ current water planning processes will be consolidated. Councils, water companies, farmers and developers are to collaborate on joined-up regional and local water plans addressing water resources, pollution control, and growth needs. A new National Water Strategy is anticipated (as the Cunliffe Review urged) to set clear long-term goals. Nine regional system planning bodies or authorities are envisaged to ensure local priorities inform investment and environmental protection.
• Financing and Governance: Reforms aim to bolster financial resilience and attract long-term investment. Government proposes giving the new regulator power to set minimum capital (equity) requirements for companies, addressing high debt levels. A formal turnaround regime will support distressed firms and ensure preparedness for Special Administration (last-resort insolvency). Ownership changes will face tougher scrutiny, the regulator would gain powers to block changes in control of companies where the new owners’ financial soundness or competence pose risks. To improve investment appeal, the weighted average cost of capital (WACC) setting may be reformed: a common methodology set by the CMA for cross-sector consistency, with the water regulator applying sector-specific inputs transparently. This seeks to reduce perceptions of overly low allowed returns and investor uncertainty.
• Competition and Market Reforms: The White Paper signals targeted competition measures. The Water Industry (Specified Infrastructure Projects) (English Undertakers) Regulations 2013 (SIPR) will be updated to streamline delivery of major projects, allowing competitive tenders for large schemes to drive efficiency. Expansion of new appointments and variations (NAVs), i.e. new entrant water companies for discrete areas, is on the agenda to spur innovation and alternatives in service delivery. Retail market reform is hinted at, potentially extending competition in retail water services (currently only non-household customers have choice). These changes aim to sharpen performance incentives but will be calibrated to avoid destabilising the core monopoly service.
• Supervision and Performance: A new Performance Improvement Regime (PIR) empowers the regulator to intervene decisively when companies underperform. Rather than waiting for 5-year price reviews, the regulator can set improvement plans or penalties mid-period to “fix failures” and protect customers and the environment. The supervisory teams assigned to each company will continuously monitor asset health, financial metrics, and compliance, effectively an ongoing “MOT” style check of pipes, pumps and infrastructure. This proactive supervision is meant to catch problems early and end the era of companies “marking their own homework” on asset resilience.
• Asset Resilience and Environment: A shift to prevention-first regulation underpins the reforms. Water firms must plan for the long-term, investing in maintenance and sewer upgrades to avert service failures. Backed by £104 billion in private investment over five years, the agenda funds renewal of aging infrastructure. The White Paper also doubles funding for local catchment partnerships to tackle pollution at source, promotes sustainable drainage and rainwater management to reduce sewer overloads, and builds on recent moves (e.g. banning plastic wet wipes) to stop pollution “upstream”. Importantly, it seeks to align overlapping environmental standards – for example, ensuring wastewater treatment rules and storm overflow targets use a single, coherent set of compliance measures. Stronger enforcement (including potential criminal liability for deliberate cover-ups of pollution) will underscore that environmental duties are on par with customer service.

What happens next?

The reform rollout is ambitious and multi-phased:

• July 2025 – Independent Commission’s final report (Cunliffe Review) published, prompting Government commitment to “take forward” key recommendations (abolishing Ofwat, new ombudsman, etc.).
• January 2026 – Defra publishes A New Vision for Water White Paper (CP 1490), detailing the full response and reform plan. This will be followed by public consultation on the proposals.
• Spring–Summer 2026 – A comprehensive Transition Plan 2026 will map out steps to implement the new regulatory model. During this period, an interim Strategic Policy Statement may be issued to Ofwat (in its final phase) to steer the transition.
• Late 2026/Early 2027 – Water Reform Bill to be introduced in Parliament. This legislation will create the new regulator and amend a host of statutes (Water Industry Act, Water Resources Act, etc.) to give effect to the White Paper’s proposals.
• Mid–Late 2027 – Target timeframe for establishing the new integrated regulator in England (assuming the legislative process and setup proceed efficiently). Previous examples (e.g. merging five regulators into Ofcom) took ~3 years and multiple Acts. If similar, the new body would emerge by 2027–28, just as the next price control (PR29) preparations begin. The Commission even floated a possible short “bridging” price control or extension of PR24 to accommodate this transition.
• 2025–2030 (PR24 period) – Incremental changes within the current cycle: Ofwat (and subsequently the new regulator) will push companies to raise equity (over £2 billion was injected by late 2025), pilot the supervisory approach on a shadow basis, and accelerate ongoing enforcement and investment (e.g. the £11bn to improve storm overflows by 2030).
• 2030 onward – The 2030–35 price control (PR29) would be set under the reformed framework if on schedule. This period is expected to fully integrate the new outcome commitments, financial resilience standards, competition mechanisms, and regional plans established by the reforms.

This timeline is subject to political and practical uncertainties. However, the direction is clear: by the late 2020s England’s water regulation should be fundamentally restructured with an integrated regulator at the helm, new checks and balances on companies, and a more coordinated planning regime in place.

Regulatory & Public Authority Perspective

From the viewpoint of regulators and public authorities, the White Paper’s agenda represents both an opportunity and a challenge in reshaping governance of the sector:

• Central Government (Defra): Defra will orchestrate the reform implementation, so its role shifts from arm’s-length oversight of Ofwat/Environment Agency to directly overseeing the creation of a new regulatory body via statute. This raises questions of statutory clarity. It may also result in Defra inadvertently playing some degree of a role in ongoing regulatory determinations (if only by way of influence). The new regulator’s mandate must reconcile economic, environmental, and consumer protection duties that previously sat across multiple bodies. Some of this is easy enough but an amended s. 2 of the Water Industry Act 1991 will be critical and changes to this core industry staple may be fraught with difficulty. Drafting the Water Reform Bill will require precision to avoid diluting any aspect (for instance, ensuring environmental regulation remains robust even as it is embedded in a multi-purpose regulator). Defra must also develop the promised National Water Strategy, setting out long-term outcomes for water resources, supply resilience, wastewater, and environmental quality. This strategy will guide both the new regulator and regional planners, and must be periodically updated. The Department will need to coordinate with the Welsh Government too, since Wales is adopting a different approach (the Commission recommended water regulation in Wales be embedded into Natural Resources Wales) – cross-border catchments and companies will entail ongoing inter-governmental liaison.
• Local Authorities and Regional Planning: A major theme is devolution of planning to regional and local levels. The plan to bring councils into regional water planning forums could empower local authorities to influence water investment decisions (e.g. linking new housing development with water resource plans). Local authorities will likely sit on the new regional water committees or authorities (the White Paper echoes the Cunliffe proposal for 9 regional water authorities). From their perspective, this integration is welcome – it promises more say in tackling issues like nutrient pollution, flood risk, and drought at a catchment scale. However, it also imposes resource burdens: councils and regional bodies must develop technical expertise to engage on complex water models, environmental trade-offs, and project appraisals. There is very little evidence on how viable this really is. There’s a risk of duplicative bureaucracy if the roles of these new regional planners versus the national regulator and the Environment Agency (which retains flood management) are not clearly demarcated. Public authorities will have to avoid an outcome where multiple plans (local, regional, company business plans, etc.) overlap confusingly. Simplification is the goal, but execution will matter. Bringing new participants in to central roles means risking repeating mistakes integration should mean improvement not a chance to make old mistakes over again.
• Existing Regulators (Ofwat, EA, DWI): Understandably, Ofwat faces abolition, and the Environment Agency (EA) and Drinking Water Inspectorate (DWI) will cede certain functions. Staff and expertise from these bodies would presumably transfer into the new regulator. However, the current climate is hugely challenging for the many dedicated public servants that work for regulators. Such change raises operational transition risks: maintaining regulatory continuity during the change. For example, ongoing price controls, enforcement cases, and improvement programs (storm overflow reductions, leakage targets, etc.) cannot pause during reorganisation. The White Paper acknowledges the need for a careful transition plan. This is absolutely right but is the whole battle and there was some hope the white paper would have more on this. Ofwat in PR24 has already set a huge investment program (~£96bn in capital expenditure for 2025–30) that must proceed under incoming oversight. Meanwhile, the EA will continue its environmental permitting and enforcement until handover; the EA Chief Executive has pledged to maintain focus on current priorities (e.g. prosecuting permit breaches) through the interim. For the EA there will be a split of function. But the white paper does not set out a schedule/list of exactly which EA functions, teams, statutory powers or regimes move across. The question of splitting EA functions between water and other functions is not simple for example consider:
  • Environmental Permitting (often integrated across water, waste, installations);
  • incident response / investigations where pollution, habitats, flood risk and waste can overlap; and
  • the interface between catchment/river basin planning and regulation.

  Public bodies will need robust change management clear timetables for migrating responsibilities, retention of key staff (to avoid a knowledge vacuum), and legal provisions to transfer existing licences, orders, and enforcement actions to the new authority seamlessly (likely via the Water Reform Act).

• Regional Water Authorities: If established as new statutory bodies, these nine authorities would coordinate at a catchment/regional level. They might be modelled on, or even built from, existing structures like regional water resource planning groups or flood committees. Public authorities must ensure that these bodies include voices from all relevant sectors – the NFU has already urged that agriculture be represented so that farmers can contribute to water planning and drought/flood solutions. The authorities will need defined powers (are they advisory or decision-making?) and funding mechanisms. There is also a question of accountability. Will these regional entities answer to the new regulator, to Defra, or be independent partnerships? Clarity here will determine how effectively they can require water companies and others to execute agreed regional plans.

In sum, from the regulator and public sector angle, A New Vision for Water demands an unprecedented level of inter-agency coordination and legislative overhaul. It does offer a chance to eliminate the siloed approach of the past – but only if roles, resources, and legal duties are aligned carefully. A real challenge is whether there is scope and resource to do this well.

Water Companies and Investors Perspective

For the regulated water companies and their investors, the White Paper is both promising and challenging. It fundamentally reshapes the regulatory contract under which they operate:

• Financeability and Returns: Water companies have long relied on stable, if modest, returns in a low-risk monopoly framework. Recent years saw returns squeezed, the Commission noted that 2020–24 WACC levels were low relative to other sectors, contributing to investor wariness. The White Paper’s response is twofold: increase allowed returns where justified (via more consistent WACC-setting and reduced performance volatility) but also lower risk by providing greater regulatory certainty. By having the CMA set common WACC parameters, the intention is to de-politicise the cost of capital and avoid protracted fights; indeed, at PR19 the CMA intervened to raise WACC for some companies. Investors may welcome this centralised guidance if it results in more predictable outcomes. However, if the CMA’s methodology is conservative, companies might actually see little uplift. Companies and their shareholders will also have to reckon with rationalised performance incentives, the plan is to simplify the outcomes framework to ~10 core metrics and limit rewards/penalties to reduce volatility. While this lowers downside risk (fewer surprise penalties), it also caps upside for outperformance. It also falls in to an age old trap of defining targets so tightly that you can’t take a longer-term view. Long-term investors who “take a low-return, low-risk approach” are explicitly preferred by the review this is good and is the right profile of risk for water companies, meaning the days of earning high equity returns through leverage or financial engineering are waning. All told, financeability will hinge on raising new equity (as several companies have started to do) and accepting steadier, bond-like returns. The upside for investors is a more sustainable sector with fewer crises, which, if achieved, could reduce the risk premium and cost of capital over time. However, reset means reset. There is no point imposing penalty after penalty and pushing our stressed water services deeper and deeper into trouble.
• Capital Structure and Risk Appetite: The likely introduction of minimum equity requirements or leverage caps is a significant shift. Highly leveraged firms (some exceeded 80% debt) will need to inject equity or restructure balance sheets, a short-term hit for owners, but intended to ensure resiliency. Companies may need to retain more earnings (dividend restrictions when performance falters are already being imposed by Ofwat) to build equity buffers. For investors, especially infrastructure funds and private equity, this is a mixed blessing: it guards against collapse (protecting value in the long run) but reduces the ability to extract cash in the short run. The new turnaround regime could also affect investor risk appetite knowing that if a company spirals toward failure, a formal intervention (potentially diluting existing equity) would occur, investors will be keen to avoid that scenario. They might therefore be more proactive in governance, supporting management to fix issues early. On the flip side, some investors could see these measures as additional regulatory intrusion, potentially deterring those seeking high-leverage high-return models. The emphasis on long-term stewardship may attract pension and sovereign wealth investors who value stability, while dissuading short-term speculative owners.
• Delivery and Operational Pressure: Water company management will experience far closer scrutiny of day-to-day operations. The White Paper’s supervisory model means each company will effectively have regulators “embedded” in their business oversight. Instead of a cycle where companies are largely left alone between five-year reviews, they will undergo continuous monitoring, asset health checks, financial stress tests, operational performance reviews, etc. This could be beneficial: a collaborative regulator that understands company-specific context might set more achievable targets and help avoid unrealistic efficiency expectations that plagued past price reviews. Moving beyond the notional company model could yield targets that are demanding for all companies, if done right. However, the risk of regulatory micromanagement looms large. Companies may feel constrained in their decision-making if every significant investment or change might be second-guessed by the supervisory team. There is also a risk of regulatory capture in reverse, i.e. regulators becoming too sympathetic to a company’s special pleading, leading to inconsistent standards across companies. Well-governed firms should thrive under greater transparency and early warning of problems, but poorly performing ones will find it harder to hide delays or failures. Notably, the PIR (Performance Improvement Regime) means swift sanctions or mandated improvement plans for laggards. Boards of water companies will need to adopt a more proactive compliance culture, knowing that the new regulator can intervene rapidly – potentially even removing directors or controlling dividends if performance endangers customers or the environment. This could alter corporate governance: expect stronger risk committees, more engineers on boards, and a focus on maintenance and resilience in corporate strategy.
• Risk and Reward Balance: A core concern for investors is whether the package of reforms improves the long-term reward-to-risk ratio. The Commission explicitly aimed to reduce the volatility of returns in the sector by simplifying outcome incentives and avoiding double-jeopardy enforcement. This reduction in volatility (and in regulatory uncertainty from open-ended investigations) is meant to lower the risk premium demanded by investors. If successful, companies could see a lower cost of capital, benefitting both shareholders (through higher asset valuations) and customers (through lower bills). However, if the integrated regulator adopts a heavy-handed approach or if political pressures persist (e.g. calls to renationalise or cap bills), the risk premium could conversely rise. International investors will watch the implementation closely – any missteps (such as confusion in the new regulator’s decision-making or protracted transition instability) might be priced in as additional risk. Encouragingly, after Ofwat’s PR24 final determinations and amidst reform signals, water companies managed to raise fresh equity – indicating investors still find the sector viable given the promise of reform. Continued clarity (for example, how the CMA-set WACC will work and how the new regulator will use its discretion) will be needed to maintain investor confidence through this transition.

In summary, water companies and their investors face a recalibration. The regulatory compact is tilting toward long-term public interest goals stability, sustainability, and resilience potentially at the expense of short-term profits and autonomy. This will work if it comes with stability Nonetheless, a more stable sector with clear rules can also benefit companies: as one industry comment put it, “everyone agrees the system has not been working… these recommendations should establish the foundations to secure our water supplies, support economic growth and end sewage pollution”. Companies that embrace the new vision, by investing in infrastructure, engaging sincerely with regulators and communities, and focusing on sustainable performance – are likely to thrive in the new regime. Those that resist may find that the era of “nowhere to hide” from poor performance has truly arrived.

PART B – INITIAL THOUGHTS

Our View: Delivery risks in Defra’s “New Vision” – where the detail now matters most

So enough with what others may think, what do we think? The white paper deliberately sets out a direction of travel rather than a fully engineered operating model. It commits to a new integrated regulator, a supervisory approach with more grip on delivery, a streamlined planning architecture, and a suite of investment and competition reforms intended to re-establish water as a “steady and stable” place for long-term capital.

For those who will have to implement the changes, public bodies, regulators, and water companies, the biggest questions are less about ambition and more about institutional design, resourcing, and accountability. The greatest risk is not that the reforms are too bold. It is that partial implementation creates an incoherent mess that is harder to navigate, slower to deliver, and ultimately worse than the current system. The detail is also everything here and there is a lot of it still to figure out. To take a water based metaphor there is a risk that we all row hard and then unfold the chart mid-channel.

In a pitch to make sure the next level of detail is delivered well we set out some thoughts below:

1. The integrated regulator: “whole-firm” regulation is only as good as statutory clarity

The White Paper is explicit that Government intends to abolish Ofwat and create a single regulator by bringing together “relevant water system functions” from Ofwat, DWI, EA and Natural England—emphasising “water functions only”. That headline is clear. The difficulty is that “water functions only” is not yet a legal definition. In practice, EA functions do not sit in neat boxes: permitting, enforcement, incident response and catchment work often cut across media and regimes. At present, the White Paper does not attempt a granular delineation of what transfers, what stays, and how interfaces will work in the messy middle (flood, habitats, waste, environmental permitting architecture). The White Paper therefore places a heavy burden on the Transition Plan and the forthcoming Water Reform Bill to provide that precision.

Why it matters: an integrated regulator will need refreshed duties capable of resolving inherent tensions—environmental protection, affordability, financeability, public health—without creating a litigation magnet. Too many equal-ranking duties can make decisions challengeable in multiple directions; too few risks leaving material outcomes ungoverned. The White Paper’s model can work—but only if the Bill produces a duty-set that is coherent, with an intelligible hierarchy and decision-making principles that courts can apply.

2. Supervision won’t happen on the cheap: resourcing is the hidden make-or-break issue

The White Paper is explicit about the shift in regulatory posture: a supervisory approach, “continuous engagement”, company-specific expertise, a risk ladder, and guardrails such as published supervision standards and a supervision manual. That is a profound change in operating model. Supervisory teams need a diverse skill mix (engineering, environmental, finance, economists) and the optimal approach is likely to be resource-intensive, not “light touch”.

This is a core practical point. Regulators are already overmatched against the delivery and technical complexity of the sector. They will be more so if supervision becomes the default mode unless the system pays for it (through levy / licence fees / budget settlement and, crucially, through the ability to recruit and retain scarce technical talent on competitive terms). Chances are we will get as much good regulation as we are willing to pay for.

Design choices in supervision will have huge consequences:

A. What is “supervision” in practice? A spectrum runs from periodic deep dives (“spot checks”) to continuous embedded oversight. Frontier suggests quarterly data may be needed to enable pre-emptive action—balancing timeliness against regulatory burden.

B. How is capture avoided? Government and Frontier both contemplate guardrails; Frontier highlights staff rotation and additional oversight as practical anti-capture measures.

C. Who makes the hard calls? The White Paper implies supervisors will influence “oversight and funding decisions” for each company—this raises governance and accountability questions that need resolving in statute and in the supervision manual.

If Government wants genuine supervisory regulation, it must be explicit about the resourcing model and publishable about what “good” looks like. Otherwise, the risk is an underpowered supervisor with increased discretion, delivering neither stability nor enforcement credibility.

3. Competition: valuable when targeted (SIPR/DPC), risky when treated as a default

The White Paper’s investment narrative leans heavily on the proposition that competition can lower financing costs and improve delivery, particularly for large assets. It proposes amending SIPR (and enabling legislation) to expand scope and flexibility, lowering thresholds so more projects can qualify and broadening beyond sewage to “all types of water infrastructure”. It also commits to evaluate SIPR and DPC over five years based on live experience.

This is a sensible direction, when applied selectively. Tideway is held up as evidence that competitive procurement reduced financing costs and benefited bill payers. That lesson should not be ignored.

However, there is a real risk of over-application. Namely, there is a risk of trying to run a railway timetable on a river. Competition can be good and for major infrastructure it is. But the line at the fringes is tough to draw and needs discussion. Once competition is seen as a default “good”, policy can drift into carving out ever more activities for third-party delivery without adequate thought to system consequences. Competition in water is not like competition in retail telecoms. The critical issue is not whether a project can be financed, it is whether the long-term system can be maintained, operated, and held accountable when things go wrong.

That is where the White Paper’s own text is telling. It recognises the accountability risk of fragmented delivery and proposes new powers for the regulator to take enforcement action against third parties operating water assets or acting on behalf of a water company, alongside statutory obligations on contracted third parties who build/operate assets. This is really good but when we move away from single points of accountability we need to be really clear that we are doing it. It’s hard to blame Thames Water for your outage if they don’t run the reservoir.

More competition for major projects is the right direction but the detail will make or break it. If we expand infrastructure providers (IPs) and special-purpose vehicles because they reduce the cost of finance, we must be equally clear on:

• who bears ultimate service continuity duties when an IP fails,
• how operational and emergency duties are allocated,
• what customers can enforce and against whom,
• and how the regulator avoids a world where accountability diffuses across a chain of contracts.

4. NAVs and retail: competition is not a panacea (and the White Paper itself signals the fragility)

Where competition is most controversial is where the track record is mixed. In water that’s NAVs and retail market structures. The White Paper’s rhetoric is upbeat without much of an evidence base. NAVs are positioned as “critical” to unlocking competition for housing delivery, and Government proposes making the regulatory framework for NAVs “more proportionate”, including improved planning guidance and a longer-term monitoring strategy.

In fairness the White Paper also provides an implicit warning flag on competition where markets are thinner: it notes the need for a new supplier of last resort mechanism to protect businesses from disruption caused by unplanned retailer exits in the Business Retail Market.

As above, competition can be useful, but fragmentation creates failure modes. If NAVs expand materially, policy must address the classic problems:

• cherry-picking of low-cost developments while incumbents retain the hardest obligations,
• misalignment between developer incentives and long-term resilience,
• and the risk that the sector ends up paying a higher risk premium if investors perceive unpredictable boundary loss and more complex system coordination.

5. System planning: promising—unless it becomes a “mash-up” of interests with no decision rights

Defra’s planning reforms are among the most attractive elements of the package: moving from 20+ plans to two core planning frameworks (water supply and water environment) supported by an enhanced regional water planning function, explicitly intended to reduce bureaucracy and join up currently siloed processes. This is huge and critical.

The White Paper also recognises the risk of bureaucracy creep and states a commitment to reduce duplication and avoid getting “bogged down” in more layers of process.

This is mostly positive but system planning is not automatically “better” unless it has:

• clear decision rights (who decides trade-offs),
• clear accountability (who is responsible when outcomes fail),
• and clear linkage to finance (who pays, and how funding follows the plan).

Whether rightly or wrongly there is no water national grid. We have geographic monopolies. We need to take decisions in that context. The White Paper says regional plans will set “investment priorities” and identify lower-cost cross-sector solutions. That is exactly where planning risks become financing risks. If planning sits in one place and the money sits somewhere else, plans can become aspirational documents rather than bankable programmes.

6. Planning and financing cannot drift apart—especially with 5-year price controls

Defra’s answer to long-termism is to retain the 5-year price review but introduce a 5/10/25-year planning approach, with price reviews as “checkpoints” rather than “delivery sprints”. This is conceptually sound, investors care about the credibility of the regulatory method over time, not just one control period. In the context of WACC with long asset lives and 5-year controls, investor confidence hinges on stability and predictability of the method.

But the move also raises practical questions:

• What legal weight will regional plans have inside the price review, cost assessment and incentives framework?
• How will conflicts be resolved between regional planning priorities and financeability constraints at individual companies?
• How are “unfunded mandates” avoided when system planning expands ambition faster than customer affordability or investor capacity can sustain?

The White Paper acknowledges the need to reduce unmanageable debt and improve resilience, and separately signals reform of appeals to make the process faster and more predictable. But none of that substitutes for the core reality: higher obligations plus tighter financial resilience expectations may require either more allowed funding, more equity, or both.

7. Where the White Paper is right—and where Government now has to land the detail

The White Paper is strongest where it:

• commits to an integrated regulator and supervisory model with real grip on delivery,
• tackles the planning jungle by moving to two frameworks and a regional function,
• and uses competition in targeted ways (SIPR/DPC), while acknowledging the need for evaluation and stronger assurance.

It is weakest (inevitably for a White Paper) where it postpones the answers to:

• how the EA carve-out works in law and practice,
• how supervision is resourced and governed,
• and how planning, funding and delivery accountability are hard-wired so they cannot drift apart.

Conclusion: Cunliffe asked the questions; the White Paper set the date; Government must now provide the answers.