Comments from the Sages, thoughts on the MRO and others
An open letter to the Pubs Code adjudicator by Peter Holden
It has to be said the Pubs Code etc regulations 2016 have had an unhappy start. Starting with the consultation over the winter, resulting in many changes and leading to the news on 6 May the latest draft was being suspended while some errors are being addressed. All of this has not helped build confidence in the regulations themselves.
In fact, the last draft of the regulations contains many curious features and what appear to be multiple drafting errors. Some of the provisions contain a logic that is difficult to follow and others seem to have been drawn up by someone not well versed in the workings of the sector.
The regulations are made under the Small Business, Enterprise and Employment Act 2015, which says advice and guidance may be given by the adjudicator in a whole range of circumstances and to different groups. Obviously, you cannot change the legislation but it would help us all if you were to give us guidance on a number of issues.
These are for starters: