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“The regulatory failures are unhelpful but perhaps the sheer number and regularity of them has made them less remarkable, such that they become ‘wallpaper’,” Waugh says.

He argues that some lawyers and licensees believe the Commission’s presentation of cases is detached from the operational reality but feel they have little option other than to accept the “regulator’s truth” when settling.

“The Commission’s approach to reporting may well create the inaccurate impression that the industry is inherently non-compliant,” he adds. A more balanced account might place failures alongside the majority of licensees that pass assessments or lead on customer wellbeing, although Waugh considers such a shift unlikely.

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David further emphasised the impact such a tax rise would have on high street workers and communities.

“They are people losing their jobs and communities losing long-established high-street businesses,” David wrote.

“These jobs matter. They matter particularly in communities where good local employment can be difficult to find.”

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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.