Executive Summary (English)

Introduction

This is the final report of the Legal Education and Training Review (LETR) research phase, which has been undertaken on behalf of the Bar Standards Board (BSB), ILEX Professional Standards (IPS) and the Solicitors Regulation Authority (SRA). It is the first sector-wide review of legal services since the Ormrod Report of 1971 (Report of the Committee on Legal Education, Cmnd 4595).

This report has been commissioned as the first stage of a wide-ranging review process that is designed to ensure that England and Wales has a system of legal services education and training (LSET) that is fit for the future, and one that advances the regulatory objectives of the Legal Services Act 2007 in the interests of society, consumers and justice.

The Review takes place against the backdrop of a legal services sector experiencing an unprecedented period of change, which has the potential over the next two decades to transform the shape of the legal services market. Global economic conditions and increasing competition will continue to provide a challenging and uncertain context for the international and domestic markets. Market liberalisation and funding reforms in the domestic legal services sector are transforming the face of consumer legal services, and influencing buyer behaviour, shaped by technological and demographic changes. These influences are already driving technological, role and process innovations within legal services, innovations with which LSET must keep pace.

The remit of the research phase has therefore been to develop a set of recommendations that will ensure three things. First, that the individual legal services providers of the future have the knowledge, skills and professional attributes to meet present and future needs of business, consumers and the public interest. Secondly, education and training providers are supported by regulation in delivering LSET that ensures the initial and continuing competence of practitioners, and thirdly, that employers have the flexibility to develop their workforce to deliver an effective and professional service to their clients.

Headline findings and recommendations

The report recognises that the current LSET system provides, for the most part, a good standard of education and training enabling the development of the core knowledge and skills needed for practice across the range of regulated professions. At the same time the research has identified a number of ways in which the quality, accessibility and flexibility of LSET need to be enhanced to ensure the system remains fit for the future. The report proposes a range of incremental but collectively significant reforms. Key recommendations will:

Quality

• strengthen requirements for education and training in legal ethics, values and professionalism, the development of management skills, communication skills, and equality and diversity;
• enhance consistency of education and training through a more robust system of learning outcomes and standards, and increased standardisation of assessment;
• place greater emphasis on assuring the continuing competence of legal service providers through a system of continuing professional development that will require practitioners more actively to plan and demonstrate the value of continuing learning;
• require regulators to gather and make available key data and information that will reduce information gaps, support decision-making by prospective entrants, consumers and employers, and increase the effective market regulation of LSET.

Access and mobility

• establish professional standards for internships and work experience;
• enhance quality and increase opportunities for career progression and mobility within paralegal work, by encouraging regulatory and representative bodies to collaborate in the development of a single voluntary system of certification/licensing for paralegal staff, based on a common set of paralegal outcomes and standards;
• provide higher quality and more accessible information on the range of legal careers and the realities of the legal services job market;
• support and monitor the development of higher apprenticeships at levels 6-7 as a non-graduate pathway into the regulated sector.

Flexibility

• expect regulators to co-operate in setting outcomes for LSET to ensure equivalence of baseline standards;
• clarify systems for accreditation of prior learning and transfer between professional routes, and ensure that these do not create unnecessary barriers to progression;
• remove requirements in training regulations that unduly restrict the development of innovative and flexible pathways to qualification, including the more effective integration of classroom- and workplace-learning.

The report does not recommend a move at this stage to greater activity-based authorisation, for reasons of potential cost and complexity, particularly within the present system of multiple regulators.

The research

The independent research team commenced work in June 2011 and this Final Report is delivered to the Review Executive in May 2013. It is a matter for each of the frontline regulators to decide, in the light of their regulatory responsibilities, what action they will take in response to the report’s recommendations.

The research was conducted in three stages, involving a literature review, analysis of the context of the legal services sector and analysis of the content of LSET and the systems and structures by which it is delivered. Research methods included: analysis of policy documents, regulations and secondary literature; qualitative research involving interviews and focus groups with 307 academics (including vocational stage academics), students, practitioners and others; quantitative research by way of an online survey attracting 1,128 respondents from the professions, the academy and other interested persons; online surveys of will writers and careers advisers and an analysis of the way in which solicitors use their time on specific tasks and skills. The research team was also provided with access to data collected by the Legal Services Board (LSB) on the consumer experience of legal services. Collectively the empirical research sought to discover both the advantages and disadvantages of the current system and what was necessary and possible for the future. Further input was provided by the work of two expert consultants: Professor Richard Susskind on future developments in legal services, and Professor Rob Wilson on future demand for employment in the legal services sector. Interim papers, presentations and stakeholder responses published during the course of the research can be found on the research website at http://letr.org.uk/.

Advisory groups

The overall conduct of the research stage of the Review was managed by a Review Executive, comprising the Chief Executive Officers of the BSB, IPS and SRA. A Consultation Steering Panel (CSP) comprising representatives of key stakeholders operated in both a consultative and advisory role with Dame Janet Gaymer and Sir Mark Potter as co-Chairs. The CSP met on six occasions to comment on and review progress and give guidance to the research team, and will meet again to consider this final report. An independent Equality, Diversity and Social Mobility Expert Advisory Group chaired by Professor Gus John was formed to advise the research team and the CSP. A symposium entitled ‘Assuring competence in a changing legal services market’ was held in Manchester on 10-11 July 2012 and benefited from the participation of a wide range of eminent contributors to legal education, practice and regulation.

The report

This report sets out the methodology and findings from the research phase, identifies the evidence on which those findings are based and presents a set of recommendations for the approved regulators and the LSB. The substantive chapters follow three broad themes of context (the social, economic, and policy environment within which LSET takes place), content (the knowledge, skills and attributes to be developed by LSET), and systems (the structures and processes informing, administrating, and facilitating LSET). The report is organised as follows:

• Chapter 1 provides an introduction to the aims, scope and methods of the LETR research phase.
• Chapter 2 looks at the background to, and current context of, legal education and training, contrasting the model of training for barristers and solicitors with those of the other professions and offers some evaluation of the strengths and weaknesses of current approaches.
• Chapter 3 focuses on trends in the legal services market and the changing regulatory landscape. The implications for LSET of projected legal workforce needs are considered, together with the emergence of new roles for regulated professionals and paralegals and key developments in the unregulated sector.
• Drawing on comparative research on other professions and in other jurisdictions Chapter 4 focuses on the identification and signalling of competence in legal services. It looks at the range of appropriate competencies or learning outcomes and the need to close perceived knowledge and skills gaps. The chapter concludes by exploring the setting of standards and the need for relevant and robust assessment practices.
• Chapter 5 develops the theme of assuring competence for the future, and considers the role of regulated titles and how title-based regulation may be supported or supplanted by more entity- or activity-based approaches. It looks at ways to increase the flexibility of routes to qualification, and the possibility of more common or integrated training between the different legal professions. It also considers the relative roles of CPD and re-accreditation in assuring continuing competence. The chapter concludes by discussing the contribution of quality assurance processes to maintaining competent performance.
• Chapter 6 focuses on four issues critical to the future development of LSET: the promotion of fair access; the assurance of continuing competence through enhanced supervised practice; a revised approach to CPD, and the possibility of increased regulation or quality recognition for paralegals. The chapter concludes by exploring a range of institutional changes intended to support information flows and cultural change in the future regulation of LSET.
• Chapter 7 summarises key findings and conclusions drawn from the research set against an equality impact assessment. It also sets out the recommendations for the regulatory bodies and identifies areas requiring further research.

Context for the recommendations

The recommendations address those aspects of LSET that have been highlighted by the research as either currently deficient or in need of reconsideration to ensure the future effectiveness of the system. Chief amongst these are:

• insufficient assurance of a consistent quality of outcomes and standards of assessment, particularly for those professions where an element of education or training is delivered by a range of semi-autonomous providers;
• limits on the acceptable forms of professional training (notably at vocational and CPD stages) which may unnecessarily impact the utility of training, inhibit innovation, or restrict competition;
• knowledge and skills gaps in respect of legal values and professional ethics, communication, management skills and equality and diversity awareness;
• limits on horizontal and vertical mobility, which may become increasingly important as the market becomes more fluid. Although numbers seeking to transfer between professions appear relatively small, there may be appreciable equality and diversity effects in restricting vertical mobility between the smaller and larger professions, and in unduly restricting paralegal access to regulated occupations. Limits on horizontal mobility may be less significant in diversity terms, but such constraints may still be difficult to justify on objective, risk-based, criteria;
• the impact of increasing cost barriers affecting access to academic, professional and workplace training particularly for solicitors and barristers in non-commercial practice;
• limitations placed on the capacity for coherent evidence-based policy-making in respect of LSET by a lack of research and information.

The overarching approach taken by the report has been to encourage incremental reform where possible, through a process in which regulators and stakeholders collaboratively ‘co-design’ LSET. This will enable the LSET system to respond strategically to change in what is likely to remain a very uncertain economic and political environment over the next decade.

Recommendations

The full recommendations are listed below. They are organised into four groups: outcomes and standards; content; structures and review process. Each set of recommendations is preceded by a brief explanation of the grounds for making them. A fuller explanation of the scope and intent of each recommendation is included in Chapter 7. There is no particular significance to the order in which the recommendations are presented, and no implications are intended with regard to the priority of any item.[1]

Outcomes and standards

The tasks of establishing, monitoring and enforcing standards of competence are central to professional regulation, and education and training are means used by regulators to achieve compliance with those standards. Competence must, therefore, be demonstrably attained, signalled and assured.

The current system of LSET does not consistently ensure that desired levels of competence are reliably and demonstrably achieved. The key weaknesses in the system are: its reliance on relatively shallow, vague or narrow conceptions of competence; too great a reliance on initial qualification as a foundation for continuing competence; insufficient clarity and consistency around standards at points of entry; the absence, in general, of robust mechanisms for standardising assessment and a lack of coherence as regards transfer and exemption between regulated titles.

The development of a more robust and systematised range of outcomes and standards, coordinated between the professions, would enhance the reliability and consistency with which competence is achieved; enable proper accreditation of prior experience and formal learning against those outcomes and facilitate greater clarity about horizontal transfer between professional routes.

Recommendation 1
Learning outcomes should be prescribed for the knowledge, skills and attributes expected of a competent member of each of the regulated professions. These outcome statements should be supported by additional standards and guidance as necessary.

Recommendation 2
Such guidance should require education and training providers to have appropriate methods in place for setting standards in assessment to ensure that students or trainees have achieved the outcomes prescribed.

Recommendation 3
Learning outcomes for prescribed qualification routes into the regulated professions should be based on occupational analysis of the range of knowledge, skills and attributes required. They should begin with a set of ‘day one’ learning outcomes that must be achieved before trainees can receive authorisation to practise. These learning outcomes could be cascaded downwards, as appropriate, to outcomes for different initial stages or levels of LSET. Learning outcomes may also be set (see below) for post-qualification activities.

Further, if the public is entitled to expect a single level of competence across at least the range of reserved activities and common core skills, there will need to be some coordination in setting threshold levels of competence. This does not mean that different pathways or qualifications must adopt common learning processes, or that qualifications cannot be set above the threshold, but it does mean that different approaches must have at least equivalent effect. It is recommended that, to assure an appropriate underlying standard, the threshold for authorisation should be at not less than level 6. Further, longer term, a national framework for the sector would simplify decisions about transfer between professions and qualification routes, and about partial authorisation. It will facilitate the development of specialist activity-based qualifications or accreditations. It could also provide a single framework to support progression from paralegal to authorised practitioner.

Recommendation 4
Mechanisms should be put in place for regulators to co-ordinate and co-operate with relevant stakeholders including members of their regulated profession, other regulators, educational providers, trainees and consumers, in the setting of learning outcomes and prescription of standards.

Recommendation 5
Longer term, further consideration should be given to the development of a common framework of learning outcomes and standards for the legal services sector as a whole.

Content

A number of gaps and deficiencies are identified in the knowledge, skills and attributes currently developed by LSET. The centrality of professional ethics and legal values to practice across the regulated workforce is one of the clearest conclusions to be drawn from the LETR research data, and yet the treatment of professional conduct, ethics and ‘professionalism’ is of variable quality across the regulated professions. There was general support in the research data for all authorised persons receiving some education in legal values and regulators are encouraged to consider developing a broad approach to this subject rather than a limited focus on conduct rules or principles.

There is strong support for properly and sensitively integrating equality and diversity training into LSET as a part of both initial and continuing education.

Skills gaps in commercial awareness, legal research skills, and communication – in particular writing and drafting and, in some contexts, advocacy – were identified in respect of the initial stages of training.

The importance of developing business and management skills is widely acknowledged as important but this is not well embedded across the sector. The research data highlighted the need to develop training in client relationship management and project management as well as in supervision of trainees and others.

Recommendation 6
LSET schemes should include appropriate learning outcomes in respect of professional ethics, legal research, and the demonstration of a range of written and oral communication skills.

Recommendation 7
The learning outcomes at initial stages of LSET should include reference (as appropriate to the individual practitioner’s role) to an understanding of the relationship between morality and law, the values underpinning the legal system, and the role of lawyers in relation to those values.

Recommendation 8
Advocacy training across the sector should pay greater attention to preparing trainees and practitioners in their role and duties as advocates when appearing against self-represented litigants.

Recommendation 9
Learning outcomes should be developed for post-qualification continuing learning in the specific areas of:

• Professional conduct and governance.
• Management skills (at the appropriate points in the practitioner’s career. This may also be targeted to high risk sectors, such as sole practice).
• Equality and diversity (not necessarily as a cyclical obligation).

A number of recommendations are made in respect of the Qualifying Law Degree (QLD) and Graduate Diploma in Law (GDL). These continue to provide an important pathway into the legal services sector for a range of authorised persons, and thus constitute an important foundation for professional training. However, the report also takes the view that the need to ensure continuing competence places the primary focus of the LETR on the later stages of initial and continuing education, and acknowledges that the QLD serves multiple purposes and should not be over-regulated.

The extent to which the Foundations of Legal Knowledge will need to change will be determined by work on the outcomes described above, and the report does not seek to pre-empt that process. The research data make no clear-cut case for either extending or reducing the existing Foundation subjects; in particular there is no consensus to include professional ethics as a discrete Foundation subject. At the same time, in the interests of transparency and consistency for students and employers alike, there is a case for providing some additional content prescription and guidance on the balance between the Foundation subjects.

Widespread concerns are noted regarding the development of legal writing, and, to a somewhat lesser extent, research and reasoning skills. A discrete assessment in the skills of research, writing and critical thinking is therefore recommended as a necessary and proportionate response.

Recommendation 10
The balance between Foundations of Legal Knowledge in the Qualifying Law Degree and Graduate Diploma in Law should be reviewed, and the statement of knowledge and skills within the Joint Statement should be reconsidered with particular regard to its consistency with the Law Benchmark statement and in the light of the other recommendations in this report. A broad content specification should be introduced for the Foundation subjects. The revised requirements should, as at present, not exceed 180 credits within a standard three-year Qualifying Law Degree course.

Recommendation 11
There should be a distinct assessment of legal research, writing and critical thinking skills at level 5 or above in the Qualifying Law Degree and in the Graduate Diploma in Law. Educational providers should retain discretion in setting the context and parameters of the task, provided that it is sufficiently substantial to give students a reasonable but challenging opportunity to demonstrate their competence.

A number of specific concerns regarding quality of training are highlighted throughout the report in relation to reserved activities, specifically advocacy and will-writing. Vocational programmes are presently caught between trying to replicate the growing range of likely future practice environments, including work in alternative contexts such as alternative business structures (ABSs), alternative roles, and rapidly developing activities such as alternative dispute resolution, and providing the depth of training that would better prepare them for a stratified and increasingly specialised marketplace. Consequently the following specific recommendations are made:

Recommendation 12
The structure of the Legal Practice Course stage 1 (for intending solicitors) should be modified with a view to increasing flexibility of delivery and the development of specialist pathways. Reduction of the breadth of the required technical knowledge-base is desirable, so as to include an appropriate focus on commercial awareness, and better preparation for alternative practice contexts. The adequacy of advocacy training and education in the preparation and drafting of wills needs to be addressed.

Recommendation 13
On the Bar Professional Training Course (for intending barristers), Resolution of Disputes out of Court should be reviewed to place greater practical emphasis on the skills required by Alternative Dispute Resolution, particularly with regard to mediation advocacy.

Structures

Periods of supervised practice

Respondents who commented on supervised practice were almost universally of the view that some element of supervised workplace training must be retained, however consistency of experience and quality of supervision remain significant issues. There was also concern that existing regulatory structures governing supervised practice inhibited useful alternative routes to qualification, which could reduce the bottleneck around training for some professions and also help to ensure that employers have the ability to train individuals in a way that suits their needs and those of their clients.

There is growing stakeholder interest in LSET structures in which trainees are able to work concurrently with formal study, not only to defray cost, but also to facilitate consistency between what is learned in both contexts and the development of attributes such as commercial awareness. Nevertheless, such blending, if compulsory, would create additional costs for smaller entities. A market-led ‘mixed economy’ is therefore proposed, in which the burden should be on the regulator, adopting a risk-based approach, to identify why a proposed route should not be permitted if the relevant learning outcomes can be achieved. This can lead to multiple routes to achieving the same outcomes.

Reforms are thus proposed that seek to balance a greater emphasis on quality assurance and supervisor training, with greater flexibility in regulating the duration of supervised practice (consistent with an outcomes-based approach to LSET), the environments within which training is permitted, and any unnecessary constraints on the nature of the person supervising.

Recommendation 14
LSET structures which allow different levels or stages (in particular formal education and periods of supervised practice) to take place concurrently should be encouraged where they do not already exist. It should not be mandated. Sequential LSET structures, where formal education is completed before starting supervised practice, should also be permitted where appropriate. In either case, consistency between what is learned in formal education and what is learned in the workplace is encouraged, and facilitated by the setting of ‘day one’ outcomes.

Recommendation 15
Definitions of minimum or normal periods of supervised practice should be reviewed in order to ensure that individuals are able to qualify or proceed into independent practice at the point of satisfying the required day one outcomes. Arrangements for periods of supervised practice should also be reviewed to remove unnecessary restrictions on training environments and organisations and to facilitate additional opportunities for qualification or independent practice.

CPD and continuing learning

While there is high quality training available and many practitioners take their commitments seriously, there was some considerable cynicism and doubt amongst respondents about the effectiveness of current, usually hours-based, continuing professional development schemes. The majority of CPD schemes in the legal services sector are out-of-line with recognised best practice in professions generally and by comparison with ‘leading edge’ schemes for lawyers in other jurisdictions. A number of barriers to effective participation, including cost, the exclusion of useful, often informal, learning activity, and difficulties for sole practitioners, small groups and organisations employing members of different professions, were identified. The potential importance of CPD to ensuring continuing competence highlights the need to create schemes that are effective at supporting useful learning and reflection, and provide appropriate quality assurance. Effective practice points to the use of an entity-led approach to quality assurance, with developmental audits as a way of ensuring schemes are properly embedded within the organisational environment. The disciplinary functions of audit should be secondary.

Recommendation 16
Supervisors of periods of supervised practice should receive suitable support and education/training in the role. This should include initial training and periodic refresher or recertification requirements.

Recommendation 17
Models of CPD that require participants to plan, implement, evaluate and reflect annually on their training needs and their learning should be adopted where they are not already in place. This approach may, but need not, prescribe minimum hours. If a time requirement is not included, a robust approach to monitoring planning and performance must be developed to ensure appropriate activity is undertaken. Where feasible, much of the supervisory task may be delegated to appropriate entities (including chambers), subject to audit.

Recommendation 18
There should be regular and appropriate supervision of CPD, and schemes should be audited to ensure that they correspond to appropriate learning outcomes. Audit should be a developmental process involving practitioners, entities and the regulator.

Recommendation 19
In the short to medium-term, regulators should cooperate with one another to facilitate the cross-recognition of CPD activities, as a step towards more cost-effective CPD and harmonisation of approaches in the longer term.

Apprentices, paralegals and work experience

Changes to gearing, recruitment patterns and the impact of the paralegal workforce are explored in Chapters 3 and 6 of the report. A number of issues of fair access and barriers to entry are discussed, including cost of training and the significance of prior work experience (eg, internship or paralegal work, which may not be easily accessible to all) in recruitment decisions. The research concludes that there is no straightforward solution to the problems of cost and numbers entering training, and expresses significant doubt as to whether these are properly matters for regulation. Both can be ameliorated, albeit only to a limited degree, by a combination of measures which increase access to information on the risks of entering professional training, awareness of alternative professional careers and training pathways, enable more flexibility in training pathways, and enhance competition.

The development of apprenticeships is also considered. These have largely been welcomed by relevant stakeholders as a means of increasing diversity, and in creating competition between training pathways, particular in terms of access to the solicitors’ profession. The extent to which these objectives will be achieved remains to be seen, but they are not a foregone conclusion. An apprenticeship pathway may also create risks to competence if an appropriate quality of workplace and classroom training cannot be maintained. The report therefore recommends continuing monitoring and evaluation of the apprenticeship pathway.

The report also considers the apparent expansion of paralegal roles, and the challenges created by a potentially growing paralegal workforce, including lack of progression from paralegal roles into qualification in the sector, and the appropriate means of regulating paralegals. Concerns about the quality of supervision and training of paralegals, and the lack of progression or professional recognition for their work are highlighted in the research data. In the context of the significant and substantial changes to both the private and public funding of legal services, there may be a role for independent paralegals in delivering well-priced quality services outside the currently regulated market. Further work should be undertaken to explore the potential of licensed paralegal schemes.

Recommendation 20
In the light of the Milburn Reports on social mobility, conduct standards and guidance governing the offering and conduct of internships and work placements should be put in place.

Recommendation 21
Work should proceed to develop higher apprenticeship qualifications at levels 5-7 as part of an additional non-graduate pathway into the regulated professions, but the quality and diversity effects of such pathways should be monitored.

Recommendation 22
Within regulated entities, there is no clearly established need to move to individual regulation of paralegals. Regulated entities must however ensure that policies and procedures are in place to deliver adequate levels of supervision and training of paralegal staff, and regulators must ensure that robust audit mechanisms provide assurance that these standards are being met. To ensure consistency and enhance opportunities for career progression and mobility within paralegal work, the development of a single voluntary system of certification/licensing for paralegal staff should also be considered, based on a common set of paralegal outcomes and standards.

Recommendation 23
Consideration should be given by the Legal Services Board and representative bodies to the role of voluntary quality schemes in assuring the standards of independent paralegal providers outside the existing scheme of regulation. The Legal Services Board may wish to consider this issue as part of its work on the reservation and regulation of general legal advice.

Information and collaboration

A recurring theme in the research data is the extent to which lawyers, students and consumers lack readily accessible information about LSET. There is a strong desire amongst students and trainees for greater transparency about the costs of training, the prospects for employment and the various pathways and training options available across the sector as a whole. There was some distrust of the impartiality of information provided by education and training providers themselves. Data also highlight some lack of awareness amongst practitioners and employers of the range of training options currently available.

Many of the developments discussed in the report are at an early stage. The longer term consequences of the emergence of ABSs, trends in the employment of paralegals, the impact of the latest legal aid changes, and the effect of university fees are difficult to predict. If regulators are to maintain a continuing evidence-based approach to regulation and policy-making there will be a continuing need for research and good quality information. The pace of change is unlikely to slow in the short to medium term. This suggests that the model of large scale, infrequent, reviews of LSET is outmoded and should be replaced by a more continuous and incremental approach. The setting of outcomes and standards described above by itself demands an increased degree of collaboration and co-operation across the sector in the context of continuing review. Consequently a number of recommendations are also made for the creation of tools and environments for information sharing, collaboration and experimentation.

Recommendation 24
Providers of legal education (including private providers) should be required to publish diversity data for their professional or vocational courses, Qualifying Law Degrees and Graduate Diplomas in Law and their equivalents.

Recommendation 25
A body, the ‘Legal Education Council’, should be established to provide a forum for the coordination of the continuing review of LSET and to advise the approved regulators on LSET regulation and effective practice. The Council should also oversee a collaborative hub of legal information resources and activities able to perform the following functions:

• Data archive (including diversity monitoring and evaluation of diversity initiatives);
• Advice shop (careers information);
• Legal Education Laboratory (supporting collaborative research and development);
• Clearing house (advertising work experience; advising on transfer regulations and reviewing disputed transfer decisions).

The review process

Although useful contributions were received from the Legal Services Consumer Panel and from in-house lawyers as buyers of legal services, there was limited consumer engagement in the LETR research phase. The consumer perspective on LSET remains underdeveloped, and should be addressed by ensuring consumer representation in the next phase of the review.

The report stops short of making specific recommendations in respect of the unregulated sector as a whole. Although some preliminary research was undertaken, this served largely to highlight the paucity of existing research and information about that sector. In the context of any potential review by government of the scope of legal services regulation, additional research into the current functioning of the unregulated sector should be commissioned as a matter of priority.

Recommendation 26
In the light of the regulatory objectives and the limited engagement by consumers and consumer organisations in the research phase of the LETR, it is recommended that the regulators ensure that appropriate consumer input and representation are integrated into the consultation and implementation activities planned for the next phase of the LETR.

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