Cunliffe Review Response: The culture of non-compliance must end

21 July 2025

The final recommendations published today from the independent review led by Sir Jon Cunliffe set out important elements of a better-managed water system in England, but Government must now go further, faster, and deeper to fix our failing waters.

Richard Benwell, member of the Independent Water Commission expert advisory group, and CEO of Wildlife and Countryside Link, said: “A culture of rule-breaking and non-compliance is blighting our water environment. Water companies continually break pollution limits and licence conditions. Intensive industry and agriculture leach toxic chemicals, slurry and sediment. It must stop.

“We need a dedicated environmental regulator that’s fierce, powerful and independent. We need an economic regulator fit to ensure public benefits are rewarded well, but pollution never pays. Any move to merge the two must make nature protection the priority.

“For years, river restoration plans have been ignored. Government should quickly set up Regional Water Authorities, with powers to set strict pollution limits and action plans for all industries, with full representation from consumers and independent experts.”

We welcome the proposed shift to Regional Water Authorities and stronger regional governance. If properly funded, resourced, and empowered, they could drive more effective delivery of river improvements, where previous River Basin Management Plans have largely been ignored. Government should support catchment partnerships to help deliver the plans and invest in better pollution monitoring across the whole water environment.

A new, legally binding overarching target for water is another critical step forward. This must be ambitious and underpinned by clear cross-sector delivery plans with interim targets. It would provide the long-term certainty that nature, communities and the sector urgently need.

However, there are key concerns about how delivery will be handled. Reforming regulators without addressing fundamental issues around resourcing and remit would mean painting over cracks instead of fixing the foundations. Regulators need stable, increased funding and a clear, consistent steer from Government.

We also caution against any reforms to the Water Framework Directive (WFD) that would dilute its core protections. Any reform must maintain the directive’s key principles and go further by:

• Maintaining the ‘one out, all out’ approach but improving the reporting process to reflect where improvements have been made on different issues
• Bringing the whole freshwater environment into scope, particularly small standing waters and headwaters
• Ensuring that there is enough funding for good implementation and enforcement

Some critical actions do not require legislation and Government implementation can begin today. Empowering catchment partnerships, rolling out comprehensive pollution monitoring, and getting new regional planning up and running should be top of the list.

Ali Morse, Water Policy Manager at The Wildlife Trusts said:
“There are some strong recommendations in the Commission’s Report for a much more integrated way of managing water, bringing together key sectors to drive progress towards regionally-apportioned targets that add up to a national whole. Crucial to the success of this will be an ability to direct funding, because at the moment we fund and deliver very similar actions through water companies, through farm funding, via environmental NGOs, when we should be far more systematic. The scale of the challenge here is vast, so we can’t afford to be siloed and ineffective any longer.

“There are also some areas of concern - such as potential changes to the overarching legislation that protects our waters, and to the functions of regulators – whilst neither are perfect, we need to be very careful about making changes that could dramatically backfire.

“But finally, and key to the future health of our waters, is Government’s response. Some of these measures it needs to put in place immediately, such as those which support working at the catchment-scale – whilst others it needs to consider carefully. Ultimately, the commission has set the framework that equips Government to act – and it must now do so with purpose if it is to demonstrate that it remains serious about improving our rivers, lakes and seas for good.”

The 2027 deadline to achieve good ecological status in all waters for the Water Framework Directive is looming, with the UK set to move away from WFD requirements from this point. So time is running out to restore our rivers, lakes and wetlands. Government must not let this opportunity drift by.