On Wednesday we held our third Form Summit at the House of Lords, which has been making UK laws since the fourteenth century. But our subject matter was the future, not the past: how do we ensure that the very best new technology gets through our regulatory system and into users’ hands as swiftly and safely as possible?

It’s two years since our ministerial launch of Fix the Regulators, our rallying cry for the UK to take this question much more seriously, and a year since the (now) AI Minister Kanishka Narayan joined our second Summit. This year, fifty startup founders, VCs, policy professionals and policymakers met over breakfast to dig further into the reality of building at the regulatory frontier - in what we call “markets that matter”.

Who better to kick us off than Lord David Willetts, chair of the government’s new Regulatory Innovation Office. The creation of the Office was a key recommendation in Fix The Regulators and it’s now just over a year old. His discussion with Leo touched on the art of making actual change in Whitehall as well as the practical, sectoral approach the RIO has taken in its first year of operation.

We then heard from a panel of those who are at the wheel, steering companies in the sometimes choppy waters between frontier technology and the frontier of government: Claire Trant (CEO, Untap Health), James Dean (CEO, stealth startup), Sarah Hunter (NED, ARIA, Trustee, NESTA) and Max Beverton-Palmer (Head of Public Policy UK, NVIDIA).

The lessons below reflect just some of what we learned, but don’t do justice to the conversations on the day, in particular between founders and policymakers that are building towards the same objectives, but haven’t found themselves in the same room - until Wednesday.

Convening these discussions will always be at the heart of what Form does. It’s becoming clearer and clearer that where tech meets policy is the defining intersection of our lives. Agentic capabilities are eating into regulated spaces: our health, our energy, our money. As technology’s influence deepens, state scrutiny will increase — and the most game-changing tech will require completely new regulatory infrastructure.

Combined with the geopolitics of today, tech is prompting more and more questions of government. We believe that it is in rooms like the Form Summit that we’ll find the answers.

Lesson 1: government sometimes gets in its own way

“Government” isn’t a single thing, it’s a web of departments, officials, politicians, regulators, funding bodies, agencies and more. We discussed how, for example, a company can benefit from grant funding from Innovate UK - but then see this capital spent down sitting in a regulatory queue that a different part of government has little incentive to speed up.

We need a more holistic view of government support - that funding, or investing in a regulated startup, should come with an expectation of joining-up across the public sector. How else could the state help this startup, rather than getting in its way, for example when it comes to regulatory authorisation? The new Sovereign AI fund is interesting in this respect, promising access to compute and other support as well as its capital.

For its part, the Regulatory Innovation Office convenes regulators, supports their efforts to innovate, provides small amounts of targeted funding (such as to create the Cell-Cultivated Products sandbox at the food regulator) and designs other novel ways to foster innovator-regulator collaboration, such as an upcoming hackathon on AI for Regulation and the launch of a “Front Door” pilot through which startups can tell the RIO about regulatory barriers.

Lesson 2: there’s a lot to “doing government well” for a tech firm

Just as government isn’t one single thing, understanding how and why government matters to a scaling tech firm has many dimensions. Product decisions, go-to-market calls, brand building efforts, events, crisis response. Politics, policy and regulation feed into each of these in nuanced ways - successful firms convert this messy, disparate picture into decisions that allow them to go faster and build with more confidence.

It’s a conversation we’ve been having throughout the year since we launched Form Scouts, a group of a dozen heads of policy at some of the world’s best-known tech firms. Over dinners and breakfasts we’ve drilled into what really drives policy value for venture backed companies.

In turn, they are conversations that have informed our next phase of expansion as a business. In her opening remarks to the Summit, Mayowa set out our intention to launch Form Advisers later this year: this is our response to seeing a wider need, beyond our portfolio, for venture-backed tech companies to get this right.

Lesson 3: public sector procurement can be a double-edged sword

Despite being infamous for painful form filling, endless timelines and last-minute mind-changing, government procurement can work, and work well. Panellists had seen that where there’s a real appetite for new technology, word can spread between departments and demand can push through to contracting, quickly. This is true at the very early stages and also for scaled tech firms, where government sales can be a large part of the revenue mix.

But watch the risk that early revenues become imbalanced towards government and - if minds change - become a precarious basis on which to scale. Ensuring private sector GTM is running in parallel is important to de-risk growth.

Lesson 4: the UK is a great place to build at the regulatory frontier

Contrary to the narrative that to scale a venture backed company means to flip to the US, founders see the UK as a world-leading place to build complex businesses in markets shaped by policy and regulation.

For example, the UK’s geospatial data - covering transport access, grid connectivity, planning rules and more - is among the best in the world, even if it is still somewhat messy and disparate. Data infrastructure is of high quality, which underpins the ability to build, at scale, not least with AI.

And unlike the US, which is in the process of gutting much of its regulatory capacity, the UK is committed to working with founders to deliver technology that will improve the lives of its users - even if there’s still a long way to go. The regulators are still in need of some fixing.

Lesson 5: sometimes you don’t want government writing things down

Frontier technologies pose novel questions of regulators: how should we regulate autonomous vehicles, or lab-grown meat, or quantum cryptography - if at all? When technology is first emerging, it can be valuable for startups when government puts rules in place - building the regulatory “track” along which they can roll, giving certainty to product roadmaps and confidence to investors.

But the opposite is also true - “early clarity” can actually lock in onerous, inflexible frameworks that prevent growth or see the economic opportunity leaked to other jurisdictions. The panel’s advice was to be very cautious of the instinct to “write things down” in new rules or regs, until everyone is very sure that they have a settled picture of how tech will evolve and what its impacts will be.

Agentic AI is a perfect example - the EU moved quickly to regulate AI, with ChatGPT dropping just as rules were being finalised; a few years later, that single “slab” of rule-making risks looking inflexible and out of date.

Lesson 6: don’t take good government initiatives for granted

We’ve seen a crop of new institutions created to support the tech ecosystem, from the RIO to the Advanced Research and Invention Agency (ARIA), to the Sovereign AI fund, the National Wealth Fund and more. But despite their long-term aims, they are contingent on ongoing political support and need to prove their worth as they go.

The VC and startup commmunity needs to engage - to get the design of these institutions right, to support them once operational, and to help them create the proof they need to survive the next changing of the political winds.

Politicians love talking about the “red tape” that constricts business and gets in the way of growth. There to be “slashed”, it’s a strangling force on business dynamism and innovation. A spate of UK government announcements in October promised various new slashings, and this week’s Budget picked up the same theme. (As it turns out the Budget wasn’t the biggest development this week for UK tech - read on to find out what was…).

At the same time, the “red tape” framing has delivered virtually no meaningful reform in decades, despite being pursued vigorously by pretty much every administration. Here’s why: “red tape” is the wrong metaphor. It’s a convenient fantasy that scores points for politicians but does nothing for growth.

Red tape implies regulation is somehow circumstantial, pointless (or even “absurd”), and only serves to get in the way. As if we woke up one morning and the economy was covered in some strange new bindweed that had emerged overnight. A rare political and economic free lunch: hated by all, economically inefficient, and dispensed with at the stroke of a deregulatory pen! If only.

There are three big failings in the red tape argument:

1. It misses the fact that regulation is a series of prior political choices, not some unintended administrative overgrowth.

2. It misses the commerce-enabling nature of regulation - it’s market infrastructure when it works well.

3. Most important of all, it stops us seeing the bigger prize: reclaiming regulation as a vehicle to deliver innovation and growth.

1. We all vote for regulation, all the time

Regulation is not an unwanted mass of growth-sapping gunk. It is a completely predictable and necessary outcome of our political system: we all vote for it, all the time. Most manifestos in most elections are lists of promises to regulate new things - mouldy houses, online harms, football finances, to name a few recent UK examples. And between elections, campaigns crop up to motivate politicians to regulate new things - such as the recent banning of XL Bully dogs.

Regulation is there because it is one of a politician’s main tools for doing the things they think they need to do, including keeping us safe from bad stuff (financial scams, poisonous food, road traffic accidents, dodgy medicines). No politician interested in keeping their job is going to leave a system less regulated - or a population less protected - than when they started. It’s never happened. If you did a chart of regulation over time, it’s up and to the right.

Every modern economy is highly regulated. Yes, including the US - moreso in many respects than Europe (cue sharp intakes of breath). President Trump is wielding more federal power over markets than at any point in living memory. Populism and regulation are natural bedfellows because regulation is usually popular.

Those who claim that regulation is circumstantial, unfortunate and unnecessary completely misunderstand why it is we have regulation and why we always will. Slashing a regulation means overturning a prior political consensus and - in the eyes of policymakers - exposing voters to risk. Show me the politician who sees the upside in that.

2. Regulation isn’t red tape, it’s market infrastructure

When we frame regulation as red tape we lose the fact that, at its purest, it’s market infrastructure. It provides the basic rails on which commerce can happen, the rules of the game without which terms cannot be struck and enforced. The creation of the British East India Company was as a joint stock company, the first device to effectively create limited liability for shareholders. This was one of the most important moments in the history of modern commerce, and was a regulation (initially de facto, via Royal Charter, and later in 1855 in actual law).

Subsequent laws have gone on to: further define corporate forms in law, limit liability, allow capital allocation, resolve insolvency, and enforce against rule-breakers. It might sound counter-intuitive, and not very “tech-bro”, but regulation is the bedrock of capitalism. Even the current proposal to create a simpler corporate environment for startups in Europe, led by EU-Inc, is itself an ask for a new Regulation (and a great idea).

Built onto this bedrock are structures of more sector-specific regulation, which can be very complicated, such as operating retail financial services or regulated medical devices. As time goes on, regulation builds the evolution of political preferences into the operation of markets, like layers of paint on a canvas.

The idea that regulation either exists or is “slashed away” is a hopelessly simplistic framing which obscures the fact that it is primarily about political choices and the infrastructure of markets. Like real-world infrastructure, it can be great (HS1) or crappy (rail in the North of England); well-maintained (airport runways) or left to rust (Thames Water pipes); cheap (wind power) or expensive (Hinkley Point); business-enabling (rural 5G) or productivity-sapping (no wifi on trains). Bad regulation isn’t red tape, it’s a Victorian road tunnel - congested, too small for modern vehicles, pothole-strewn and poorly ventilated.

3. Upgrading our regulatory infrastructure

Like infrastructure, regulation needs careful design, committed investment and regular upgrading to meet the needs of a changing economy. This week’s report on rethinking nuclear regulation by John Fingleton, a longstanding friend of Form, is the best blueprint for this kind of approach we’ve ever seen. Because of that, it’s by far the most significant policy development this week. It doesn’t mention the phrase “red tape” once.

What does this mean in practice? To stretch our infrastructure metaphor:

1. Building new regulatory “track”. This is usually the case when new technologies are created for which there is no regulatory framework. Singapore is at the vanguard of the global alt proteins industry (within the wider novel foods segment) because it has invested in building the regulatory infrastructure for that market to exist - laying new regulatory track ahead of the technological train. The UK has dithered, as it has done with stablecoins, where we still await a regulatory framework. Growth in these sectors is directly correlated to the speed at which new rules are created, and their quality.

2. Updating existing track. When we invented electric trains we had to electrify the track. Medical devices that incorporate AI largely break existing approaches to device approval (one-off authorisations) because they evolve and learn over time. It is crucial that regulations like this are updated as quickly as it becomes clear that they are no longer fit for purpose. As a rule of thumb, any regulatory framework that is over five years old should be assumed to be likely to be inadequate for new technologies. Those frameworks are not “red tape” and “slashing” them makes no sense: they are old railways that need electrification.

3. How existing tracks are operated. A rail line that allows one train per hour at 50mph is different to one that allows five trains per hour at 150mph, but it’s the same underlying track. How regulators operate the rails they already have can create wildly different outcomes for companies. This includes the chronically slow processing of licensing approvals/applications (e.g. at the UK financial regulator, where 12 months is seen as acceptable), highly inflexible approaches (e.g. a lack of pre-submission consultation by the food standards regulator), overly-aggressive enforcement (by HMRC on R&D tax credit claims), or simply a lack of clarity about what is needed. Again, this isn’t about slashing certain rules: it’s about rethinking what the pro-growth operation of regulatory frameworks looks like and holding regulators accountable.

4. How tracks combine. City planning is based around a multi-modal understanding of transport: the way that airports, rail hubs, light metro systems, roads and active travel (cycling, etc) interact to deliver an overall system. Similarly, companies innovating at the intersection of different regulatory frameworks struggle with regulators’ inability to think and act outside their siloes. One regulator may grant a licence only for another to deny, without any consideration of their mutual role in either bringing a technology to market or preventing it. If we want to have small modular reactors manufactured in shipyards and floating in offshore constellations (even to decide if this is a good idea or not), we probably need a dozen regulators to get round the table, some of whom have never interacted before. Regulators should be heavily incentivised to coalesce rapidly around new technologies and should be held accountable for failing to do so.

Ask startups, innovators and the wider business community for their grumbles about regulation and they will almost always fall into one or more of these categories. What you almost never hear is them point to a specific regulation to be “slashed” - hence the almost complete failure of successive “red tape challenges” run by government. And the abject failure to deliver on the Brexit promise to remove the EU “red tape” that was supposedly holding back the UK economy.

Business people do often complain about a regulator itself - the institution. But this is still usually a shorthand for one of the categories above. A bit like the red tape myth, the demonisation of regulators as institutions (and sometimes their senior staff - as the former CMA chairman recently found out) is a way of having a noisy but largely unproductive conversation. Cutting the number of regulators, or merging them, or replacing their senior team, does very little to speak to the issues which are almost always about the frameworks that those regulators oversee, and how they implement them.

It’s politics, all the way down

Instead, we need to recognise that regulation is the delivery tool for political and policy choices made by elected officials and governments. In turn, politicians need to grip the choices that fall to them, and stop hiding behind the assertion that regulators are “independent” of politics. They may be independent in how they operate the rules set by politicians, but politicians made those rules in the first place. Almost the first line of John’s nuclear report, in his letter to the Prime Minister, calls out “insufficient and inconsistent political risk appetite”. He understands that this is as much about politics as it is regulation.

This problem is particularly acute for bringing to market new, disruptive technologies. Because the regulation of this tech is seen as an administrative, operational issue for regulators to work out (the realm of “red tape”), we miss the risk-weighted trade-offs that politicians must make in assessing the growth and potential harms presented by new tech. Regulators dither without political direction and cover, while politicians hide behind regulatory inertia as the reason that new regulatory track is not being built.

The new AI Growth Lab proposed by the UK science department is a potentially exciting way of breaking the current impasse, which is why we were happy to lend our support to its launch comms, along with two of our portfolio companies. It recognises that leaving individual regulators to figure out how to regulate AI innovation is unlikely to promote growth, so a more experimental, risk-tolerant approach is needed, where the trade-offs are made visible and considered. Crucial to this will be a hotline to ministers who are capable of providing the political cover necessary to ensure that when the Lab wants to make pro-growth, risk-weighted decisions, it can do that, at speed. Choosing risk, choosing growth.

But until we slash the red tape myth, we’re unlikely to get much further.

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A year ago, we published “Fix The Regulators”, a manifesto for overhauling the sclerotic regulatory state that unduly constricts growth and innovation in the UK. Crucially, this wasn’t about “cutting red tape” but was a far deeper look at regulators’ risk appetite, their resourcing, and the rules they operate by.

A year on, regulating for growth has become a core plank of the new government’s growth agenda. Ministers realise that their fiscal straightjacket makes regulation one of the most promising levers they have. But the thinking is embryonic and the delivery is yet to come - we’re still far from having fixed the regulators and most of the opportunity lies ahead.

Here’s a stocktake one year in - what’s going well, what’s not, and where we need to go next.

Fixing

✅ The new administration created the Regulatory Innovation Office (recommendation #1).

✅ The Chancellor used her strategic steer to the FCA to call on it to prioritise growth - precisely the bolder growth-focused use of these steers that we called for (recommendation #4).

✅ Rachel Reeves also set the regulators Christmas homework on the 24th December, via a letter calling for their ideas to enhance growth (recommendation #4), before summoning them to No11 Downing Street to discuss the answers.

✅ The AI Opportunities Action plan called for regulators to be adequately resourced to deal with the challenge of regulating AI in a way that promotes innovation (recommendation #3).

Trying

🤷 The Industrial Strategy consultation published in October asked some tentative questions about the role of regulation and mentioned the RIO. We need to get well beyond this toe-dipping.

🤷 The Prime Minister wrote an article in The Times in late January committing to tackle a “morass of regulation”. He was talking almost exclusively about barriers to building physical infrastructure and housing, where reform is definitely needed. But “red tape” is not the issue for rest of the economy, nor for innovative startups.

🤷 The Business Secretary took aim at the FCA’s flagship regulatory creation, the Consumer Duty, to which the FCA chief executive fired back on the need for a “metric for tolerable failure”. It’s great that this conversation is happening (recommendation #4), but it shouldn’t be happening in public nor after the fact. More on this below.

🤷 The Chairman of the UK’s competition and consumer body, the CMA, was ousted in an unusual intervention which has sent reverberations through the business and policy communities. Certainly bold, but no substitute for ministers being clear about the political direction they are giving the CMA - the strategic steer published this week in draft form asks the CMA to “take particular care to ensure growth and innovation benefits are prioritised”, which is a start.

🤷 The UK declined to sign the global declaration on AI agreed in Paris this week by 60 countries. This is mainly about geopolitical signalling, particularly to the Trump administration, but the focus on national security as grounds for not signing is concerning if it leads the UK to be more closed and interventionist in the way that AI is used and developed in the UK.

Missing

❌ Tackling the bottlenecks our regulators create. We called on government to make the UK the place that has the fastest regulatory approval timelines in the world, including new “pay for speed” options for applicants and new international recognition procedures (recommendation #1).

❌ Funding regulators to upgrade capability to “do innovation”. The RIO launched with a £1.6m pot for the Food Standards Agency to create a new sandbox for cell-cultivated products. Regulators need far more than this - permanent new innovation budgets and a new £100m pot specifically to take opportunities around new technologies (recommendation #3). This is a tiny amount in the fiscal context.

❌ An overall strategy under which disparate actions are housed - rather than Ministers freelancing on regulatory reform, largely tied to speech cycles and the comms grid.

Where next?

2025 is a “do or die” year for UK growth. The window to make changes that will have a meaningful impact in this Parliament is rapidly closing. Ministers need to seize on the decent start made above and quickly:

1. Define a plan, quickly. Bring together the aryhthmic spasms of “regulation can help growth” (see above) into a coherent plan that sits at the heart of the forthcoming industrial strategy. This is worthwhile even if just for the sake of optics and business confidence, but also because it is core to the UK’s ability to become the destination of choice for new technologies (see 6, below).

2. Clear the backlog. Provide funding for every regulator to clear its authorisation backlog on a one-off basis, thereby bringing a year (or more’s) worth of new businesses into market in one go. Lord O’Shaughnessey did this for the egregious clinical trials backlog at the MHRA - it requires focus, funding and political commitment - but the growth rewards are there.

3. Fund the regulators. Recognise the huge ROI in putting a modest amount into regulatory capacity - £100m - to take the unnecessary resource constraint off the table. This includes allowing regulators to baseline a “one month, not 12 months” approach to authorising new firms, as well as bringing in the expertise and capacity to develop routes to market for new tech & business models. Ignore siren calls, like this one from Andy Haldane, to cut regulatory budgets on the vague guise that this will somehow lead to “less regulation”.

4. Ensure the RIO is a capable, respected and impactful body in Whitehall. The RIO has around six months to prove its worth; that needs quick, demonstrable wins but also the clout in government to get things done - sticks as well as carrots.

5. Take the “but we’d need to change primary legislation…” push-back off the table. If necessary, move quickly to create a Regulators Bill that deals with any legislative barriers to ensuring regulators can become growth-promoting, not just safety-optimised. At the same time, implement our recommendation to create a mechanism to surface, triage and prioritise legislative change requests from regulators on an ongoing basis.

6. Create and delegate risk budgets. Quantify the level of acceptable risk that regulators can take in pursuit of growth and innovation (trading off against safety/other objectives) and explicitly delegate these, from Ministers to regulators. Unless ministers are prepared to provide political cover for considered regulatory risk-taking, regulators have no incentive to do so - and won’t. This will need the creation of new metrics to capture the benefits of innovation (and the downside of innovation foregone) that can be quantified. This is complicated but possible.

7. Adopt a “window” based view of new technologies and their regulation. The UK is choosing to let the cellular agriculture opportunity pass the UK by, by failing to equip the regulator to do what’s necessary to create new regulatory pathways and approve new innovation. Applicant firms have been stuck in the first (month long) phase of the authorisation process for 14 months. The Singapore and the US will almost certainly now win this market. Windows of time for the UK to become the place for new economic activities come and go - inaction is just as much of a choice as action, so we need to be clearer about which windows are open, which are coming up - and which we choose to allow to close. This is what industrial strategy means for a developed, fiscally constrained economy.

Since then, we launched Fix The Regulators, our campaign spotlighting how creaking regulatory capacity is holding back founders from scaling their impact. We got both Conservatives and Labour onboard, interviewed Patrick Vallance about this issue before he became a Minister, and then yesterday:

We’re big fans of this announcement and think there’s a huge opportunity for this new Regulatory Innovation Office (RIO) to tackle regulatory barriers and accelerate startups’ route to market. Initially it’ll be focused on:

• engineering biology🥩

• AI in healthcare 🏥

• drones ✈️ & autonomous vehicles 🚘

• space 🛰️

So, great news! But we won’t rest until the RIO genuinely leads to a different environment for startups…and there’s still a lot of detail to be worked out.

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3 thoughts on how to make the RIO succeed from here:

1. The RIO needs empowering politically & financially

As we discussed in the Financial Times, the RIO will only make the impact we need if it has two key ingredients: political backing — proper Ministerial and PM-level buy-in — and financial backing from HMT (ideally £100m, akin to the AI Safety Institute). It remains to be seen if we have either, both, or neither.

2. Prove the model to win that backing

The initial priority sectors are great choices, but to genuinely prove the model and make a difference, it will need to both narrow down — i.e. focus not just on ‘AI in healthcare’, but accelerating fully-automated diagnostic services like Flok Health to release pressure on health systems — and run hard: initially, the RIO has just been formed as the merger of two teams who had already been working on these issues. To generate a real stepchange, we need a high-urgency, focused, empowered approach to make progress.

3. Unlock new sectors and upgrade existing markets

The initial focus on novel, emerging sectors is great, but we’d also like to see the RIO work on supporting companies in existing markets where barriers to innovation have grown (e.g. fintech, nuclear). This is also where the political and growth wins will be during this Parliament 👀

If you’re building in an area overlapping with the RIO, or you’re in another sector that faces similar challenges, we’d love to hear from you and help share feedback with the RIO team. And if you’re really interested, check out ’s longer report out for UK Day One, a new campaign focused on science and tech for UK progress, about how to make the RIO a success:

Fix The Regulators is our campaign to radically rethink how we regulate and enable innovation. We announced FTR at the inaugural Future of Regulated Markets (FORM) Summit with Lord Johnson, Minister for Investment and Regulatory Reform in the British government at the time, and >75 investors, founders and policymakers.

💡Executive summary

Creaking regulatory capacity is constraining economic and startup growth, slowing innovation in the sectors that matter most to people’s lives, and becoming a rate limiter on UK startup and tech progress.

Startups and investors have long campaigned for better capital and talent policy to support the tech ecosystem. But a further category has been neglected: regulatory agility. Regulators stand between an ever-growing number of UK startups and their customers, and for many this is now their biggest barrier to growth and commercialisation.

Now, we need to massively reset our ambition. The UK should aim for new products to be licensed more quickly than anywhere in the world, with agile permissions that pivot in line with the product. We can massively reduce friction for founders, without lowering standards for customers.

Fixing this does not require major investment or legislation, but would have an enormous impact on crowding in private investment, helping companies to scale, and underpinning economic growth. It is time to take that opportunity seriously.

✅Manifesto

1. The UK should set an ambition to have the fastest regulatory approval timelines in the world

1. Introduce a ‘pay for speed’ option, including for regulators that are not usually funded by industry and where application fees are usually free, to secure a speedy decision with guaranteed fee refunds where an ambitious timeline is not met. (This is risk-free: either it improves speed and allows for investment in capacity, or applicants revert to standard pricing, but it should not lead to higher prices for the same or worse outcomes.)

2. Expand international recognition procedures where novel and frontier technologies have already been internationally authorised in other trusted jurisdictions (such as the US, Europe, and Singapore), reducing domestic regulatory burden and expediting approvals for domestic products, devices and services

2. Put innovation at the heart of regulatory policy in government by creating a new Regulatory Innovation Unit and reinforcing other existing institutions

1. Establish a joint No 10-Cabinet Office-DSIT unit to drive regulatory innovation across government by:

   1. Surfacing, triaging and prioritising legislative change requests from regulators.

   2. Keeping a public register of strategic steers requested by regulators

   3. Requiring departments to explain why pro-innovation changes have not been taken forward

   4. Monitoring regulatory performance, with the NAO and ONS, to explicitly encourage regulatory innovation by tracking approval backlogs and regulatory budgets over time, building comparable performance indicators, and estimating the cost of delayed and foregone innovation

   5. Exploring how this unit could become a radically new, cross-sectoral innovation regulator, as a long-term solution for frontier, disruptive innovations test the limits of legacy, sectoral regulator structures

2. Beef up the Regulatory Horizons Council, by:

   1. requiring that government responds to RHC reports within 1 month

   2. aligning funding decisions from the Regulatory Pioneers Fund with RHC advice, to accelerate implementation of its recommendations

   3. creating an RHC-investor panel, as recommended in the RHC’s own Closing the Gap report, to ensure RHC activity is continually based on insight and feedback from the technology frontier

3. Expand the Digital Regulation Cooperation Forum (DRCF), which only includes 4 regulators, into a wider, Technology Regulation Cooperation Forum (TRCF). This should incorporate other regulators at the frontier of AI and technology, such as the MHRA, CAA and VCA, and report into the new Regulatory Innovation Unit.

3. Fund sectoral regulators to upgrade capability

1. For regulators financed at least in-part by the government, the Treasury should permanently uplift funding to restore their 2021 budgets in real terms to recoup core, ‘business as usual’ capacity, and also commit to annual, inflation-linked budget increases to accelerate new efforts. Both could be funded via the government’s £15bn R&D budget.

2. Expand the Regulatory Pioneers Fund to £50m initially, in time rising to £100m+, to provide dedicated surge capacity for regulatory innovation projects on top of core funding increases.

4. Reset regulatory risk appetite in favour of innovation

1. Departmental Ministers should issue a strategic steer to their sponsored regulators, committing to the view that short-term conservatism ultimately leaves consumers worse off. This should provide the political cover necessary to improve competition and unlock the innovation necessary for improved outcomes

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⚡Why this matters

Fixing the UK’s regulators is essential to unlocking innovation in the sectors that most affect people’s lives, crowding in private investment, and securing future growth and industries in the UK.

Startups are increasingly coming to the fore as engines of progress, proving how small, tightly coordinated teams can have an outsized impact on the world. Indeed, most of the UK’s startup successes today have been in regulated markets like fintech, healthcare, energy and transport. These are ‘markets that matter’, where policymakers and founders can partner in the public interest. And now, the next generation are both innovating in traditional regulated markets and creating entirely new industries that could transform our lives, such as AI, cell-cultivated food, and carbon markets.

Startups are not arms of the state, ****but unlocking their breakthrough potential must be a priority for any government. Progress in AI, bio, food, health, finance, transport and many other sectors is core to the UK’s economic growth. It’s also critical that the UK has a stake in the future of these globally important sectors. Agile, effective regulators are critical to this: while UK regulators are creaking, Singapore and the US are already tempting UK companies in sectors like alternative proteins to relocate, not least because they have moved more quickly to regulate and provide innovators with an efficient, quality authorisation service.

Although the UK cannot and should not always compete on market size or government subsidies, we can become the best place for startups to design, test and bring products to market, in partnership with regulators. Post-Brexit, the UK has no excuse but to build this regulatory advantage: and critically this is not purely about deregulation, but about improving speed and agility independently of any specific rule changes or thresholds. We can be ambitious and impatient about this necessary structural reform, without lowering standards.

Getting this right would then crowd in private investment. As the Harrington Review on Foreign Direct Investment set out:

“the UK needs to recognise the importance of its regulators as engines of growth post-Brexit, and resource them accordingly as investments for future returns. Investing in regulators, when added to clear direction, consistency and accountability, is likely to be a highly effective use of public resources to attract investment.” Lord Harrington, The Harrington Review of Foreign Direct Investment

For all the hand-wringing about industrial strategy and our response to the US Inflation Reduction Act, it is regulatory agility and ambition that can make the biggest difference to our economic outlook.

Finally, weak regulatory capacity is quickly becoming a major constraint on broader science, technology and competition policy. For all the merited focus on ‘inputs’ to UK innovation and international competitiveness – capital, visas, spinouts, etc. – these levers are increasingly blunted by regulatory bottlenecks and backlogs, artificially limiting the potential of this support. While entrepreneurs in the ‘markets that matter’ are holding up their end of the bargain, regulators are increasingly unable to move as quickly as the public interest demands – entrenching incumbents who feel little pressure to deliver better for consumers.

Startups cite regulation as a key concern, State of European Tech 2023, Atomico

3️⃣The three big issues

Fixing our regulators and empowering startups means tackling three issues that hold regulators back:

1. Resource: investing in regulatory capacity to understand and approve new technology

2. Rule changes: creating flex where novel tech is constrained by legacy laws and regulations

3. Risk appetite: giving regulators the incentive and political cover to take measured risks

Issue 1: Resource

UK regulatory speed is now creaking under the weight of two generational challenges:

1. Post-Brexit, UK regulators have had to take on many new responsibilities. When demand for the ‘day job’ grows, this squeezes out space for enabling innovation.

2. Frontier, accelerating technologies, such as AI or cell-cultivated food, have massively increased the learning curve required of regulators.

But resource has not increased commensurately: in 2021, the MHRA, after hiring 7.5% additional staff post-Brexit, then faced having to make up to 25% of its staff redundant; Ofgem staff were forced to reapply for their jobs during the energy crisis; and the Food Standards Agency (FSA) has had its budget frozen for 3 years until 2025, in effect facing a £30-40m real terms cut. Emily Miles, CEO of the FSA, has commented that:

"We really want to be able to respond to innovative and emerging food technologies but our current resource constraints and the legal strictures of the current regimes mean we can’t do as much as we’d like." Emily Miles, CEO, Food Standards Agency

These resource constraints are particularly pronounced when hiring for staff with experience of frontier technologies. Although regulators often have more flexible pay bands compared to the civil service, they are still limited. And necessarily, the talent pool of people who understand frontier technologies is small, and even smaller for those who want to work for a regulator. Some large regulators might succeed – when Ofcom was given powers over online safety, they could hire from a growing Trust & Safety industry – but others which are smaller but no less critical may find recruitment much harder. This includes authorities like the Vehicle Certification Agency, which will be the responsible authority for autonomous vehicles.

In contrast, there are demonstrable benefits when institutional capacity is prioritised. Akin to ARIA, the AI Safety Institute (/Frontier AI Taskforce) was well-resourced from Day 1 (£100m) taking the resource question off the table. It also recruited senior leaders from the tech sector to drive work forward quickly. Combined, this effort established the UK as a leading voice in AI Safety while also accelerating the clarity necessary for AI companies to grow.

More recently, the government has committed £10m to upgrade AI regulatory capacity, recognising that resource is becoming an issue for both companies and authorities alike. But this is a rounding error in government spending on science and technology. £10m is the same amount received by the MHRA in the Spring 2023 budget: although senior industry figures state that this ‘does not touch the sides’ of the MHRA’s resource challenges, it has nevertheless made solid progress in clearing a backlog of clinical trials, accelerating its Software and AI medical device guidance in partnership with the FDA and Health Canada, confirming a new AI sandbox specifically for medical devices and **finally launching the Innovative Devices Access Pathway pilot. In contrast, £10m to upgrade capacity at all AI regulators is clearly sub-scale.

Relative to the c£15 billion spent annually by government on upstream R&D, science and technology, the budget for downstream regulators to help get these innovations to market is minimal. The Regulatory Pioneers Fund (RPF) – which funds individual projects by regulators to support business innovation – is a meagre £12m. After three rounds of funding since 2021, its future is unsecure, despite officials across Whitehall recommending its expansion. This isn’t nearly sufficient to accelerate a backlog of regulatory innovation projects, and does little to plug wider resource gaps. However, given regulatory funding is fragmented between different sponsoring departments, the RPF is also one of the few cross-departmental funding levers available to fix a regulatory capacity gap that has now become cross-sectoral. It should be scaled up significantly, at minimum to £50m and in time rising to £100m+.

A further solution could be to allow more regulators to raise their own revenues, as recommended by the Lords Committee on Industry & Regulators. The Vehicle Certification Agency and NICE Advice are just some of the authorities that have powers to generate income via technical advisory services to industry, and this model could be expanded subject to strict firewalls between this advice and core authorisation processes. Other regulators’ core funding already comes from charges and levies on industry, such as application fees, which provides a mechanism to scale resources in proportion with growing demand. But companies cannot be left paying higher costs for equivalent, or worsening, services. Instead, borrowing from proposals to the planning system, regulators should provide a ‘pay for speed’ option where a higher fee guarantees a quicker service: companies that value an accelerated approvals option could pay for it, but they’re refunded if the guarantee is not met.

The regulatory funding gap is neglected in policy debates about UK science & technology, but entirely solvable. And while there are other constraints on regulatory speed and capacity, lack of resource must at minimum be taken off the table as a blocker.

Issue 2: Rule changes

Other regulators are constrained by the rules they operate within, even if they have the resources and risk appetite to drive innovation.

• Until the Automated Vehicles Bill 2023 was introduced to Parliament, the vehicle safety regulator, the Vehicle Certification Agency, could not push on with approving a broad range of autonomous vehicles. In 2022, a Transport Bill was proposed, which would have legalised autonomous vehicles in the UK, but it was then pulled. Only once manufacturers, developers and insurers had comprehensive legislation, rather than piecemeal promises, did they have confidence that autonomous vehicles could be brought to market at scale with a trusted liability framework. In turn, this accelerates regulator expertise which in turn drives industry confidence and investment, deepening the UK’s competitive advantage – akin to Singapore’s approach to cell-cultivated foods.

• Similarly, in the food sector, a genuine benefit of Brexit regulatory freedoms was the ability for the UK to permit gene editing in plants and animals – a step which the EU is now also moving towards. The Precision Breeding (Genetic Technologies) Act 2023 may prove to be an excellent source of competitive advantage, with food technology companies getting started or accelerating their efforts in the UK due to this legislative momentum. But now it falls to the Food Standards Agency to actually design and implement the new regulatory regimes created by the Act, and this has been slow going due to limited resource, despite their ambition. It also has plans to reform EU-inherited rules around 'novel foods' and the application process, but again struggles to do so quickly due to resource constraints.

• Finally, the Human Fertilisation & Embryology Authority (HFEA) is now explicitly asking for changes to the HFE Act 1990 to give them “greater discretion to support innovation in [fertility] treatment and research”.

All three examples highlight how, where deregulation or new rules are required to keep pace with technology, this too requires investment: both of scarce ministerial and parliamentary time, and of regulatory capacity to establish new systems once the law changes. Yet although regulators are the first to see where existing rules prevent them approving new innovation, this insight often remains buried within government for months or years.

The Department for Business and Trade’s exploration of ‘international fast track’ pathways and targets for regulatory approvals – combined with a ‘productivity lock’ to continually ratchet up targets – is welcome. This could accelerate approvals for all of the sectors highlighted here, as well as others such as nuclear: recognising reactor designs such as South Korea’s KEPCO APR-1400, a tried-and-tested approach which was approved by the US in 2019, could reduce the cost of new nuclear plants by up to 5x.

These mutual recognition procedures should be expanded where it can clearly unlock innovation. Where trusted jurisdictions such as the US, Europe and Singapore have already approved novel and frontier technologies, the UK should implement a ‘mutual recognition ratchet’ to expedite UK approvals and reduce burden on domestic regulators.

Issue 3: Risk appetite

Some regulators have both the resource and legislative flexibility to enable innovation, but lack the risk appetite, ambition and incentives to do so. Regulators prioritise their duty to protect consumers over any other considerations, such as competition, innovation, or growth. The rationale for this is understandable: the Civil Aviation Authority’s main concern is ensuring aviation safety, while the Financial Conduct Authority reasonably wants to prevent harms to consumers. Resource constraints also compound this nervousness: if decisionmakers have limited expertise and even less time to acquire it, delay and denial of authorisation is the path of least resistance.

What is missing is an understanding that this focus on safety and market stability comes at a price. Not only does it restrict the UK’s ability to build the next generation of globally-significant companies, but it also downplays the long term benefits that competition and innovation generate for consumers. Dominant players that operate free from competition have little incentive to improve outcomes for consumers, while regulatory bottlenecks also slow transformational innovation, which primarily comes from startups, not legacy incumbents. Medicine deliveries-by-drone, manufacturing in space, real-time credit bureaus, autonomous vehicles and many more products in both frontier and traditional regulated markets take far longer to come to market than they should, with society bearing the hidden cost of these foregone benefits.

Avoiding the “stability of the graveyard”

In this context, the government’s commitment to extending the Growth Duty to Ofcom, Ofwat and Ofgem is positive – in the sense that it may encourage these regulators to consider growth impact in its decisions, having not done so explicitly before – but in practice may simply lead to regulators ‘rebadging’ existing work as contributing to these new duties. The net effect is little change in behaviour, and further administrative burden on regulators.

The FCA argues its stronger approach to new authorisations is important for deterring consumer harms, but the methodology behind the analysis they commissioned to support this stance reveals precisely its lack of interest in innovation. No potential consumer benefits from authorising new firms are considered at all, so nothing is compared against the estimated value of ‘deterred harms’– while several assumptions are also made that seriously risk over-stating the value of ‘prevented harm’. This logic results in the creation of what former Chancellor George Osborne called “the stability of the graveyard”.

This defensiveness represents an extraordinary change in the FCA’s regulatory culture since 2016, when regulators, industry & government came together to make the UK 'fintech capital of the world'. This compact worked, delivering a group of globally-leading companies and putting the UK second only to the US in terms of the vibrancy of its startup ecosystem.  Yet ten years on, this spirit of innovation and regulatory capacity has stalled.

In nominal terms, at least, the FCA has a reasonably large budget. While it has certainly had resource challenges, it is at least reasonable for policymakers to question the value the FCA is getting from its budget before raising industry fees (though this option should be kept in reserve).

Resetting risk appetites

Instead, regulators in this ‘low ambition’ category need political instruction and cover to prioritise innovation and take risks. Even the FCA is now calling for “a wider debate between policymakers, industry and consumers … about what we are willing to risk in search of innovation and better products and services”.

One way forward is for Ministers to systematically use periodic steers more frequently. Recent letters from departmental Secretaries of State focused on AI are a good start, but AI is not the only relevant technology at risk of being held back by regulators and one-off letter writing is not an adequate regulatory strategy.

To empower leaders to identify and challenge risk aversion, we also need timely, quality performance data for different sectoral authorities. But this is often either hard to find, lacking altogether, or hard to compare between regulators. At minimum, the ONS and NAO, together with regulators, should therefore collect, analyse and audit the following data:

1. A time series dataset of all regulators’ annual budgets, including tracking the share of funding that comes from industry fees vs government grants, as well as staff numbers and turnover

   1. The NAO occasionally produces a ‘Departmental Overview’ of major regulators, but this is irregular and only covers major regulators. Instead, more timely and comprehensive data would cover every regulator, including smaller regulators responsible who still have major responsibilities for enabling frontier innovation, e.g. the Civil Aviation Authority and Vehicle Certification Agency.

2. A time series dataset of regulatory performance and backlogs, including:

   1. Authorisation timescales for different permissions, demarcated into different types of applicants, e.g. for the FCA: new licence permission/senior manager/investor vs bank/consumer credit/insurance applicants

   2. Authorisation rates: existing KPIs such as ‘approval rate within 12 months' are easy to game, since it’s not always clear when the regulator deems an application ‘complete’ – especially when there is protracted back and forth – so it’s easy to ‘start the clock’ late in the process.

3. International comparison of regulator budgets: e.g. MHRA and FSA budgets in 2021 totalled roughly £300m, compared to the US Food & Drug Administration’s budget of $7.2bn. Even on a ‘share of GDP’ basis, and accounting for the US’s different healthcare structure, there is an enormous gap.

Collecting this data would also empower policymakers, the NAO and regulators themselves to conduct better ‘innovation tests’ that estimate the costs of historical ‘foregone innovation’, and thus incentivise faster and more permissive approvals regimes going forward. This would plug a gap in regulator analysis equivalent to the CMA’s counterfactual analysis conducted during merger control investigations, or the Better Regulation Executive’s ‘Equivalised Annual Net Direct Cost to Business’ (EANDCB) metric.

Notably, from the limited data that is available, it is possible to see a rough correlation between regulators funded at least in part by government and those where funding is the issue (e.g. Food Standards, MHRA, and the Environment Agency), compared with those funded by industry where a lack of risk appetite is the issue (e.g. FCA, Ofwat, Ofgem).

Table: 2020-21 Budgets of major regulators, sorted by % share of funding from government (source: NAO Departmental Overview 2020-21: Regulation report)

🏗️New levers and institutions

Although regulatory reform is a perennial policy issue, too often it is tackled through distracting ‘red tape challenges’ or ‘one in, one out’ deregulatory mantras. Instead the focus should be about building a continuous, durable capability to understand the frontier of innovation, identify appropriate regulatory reforms, and deliver them as quickly as possible.

To that end, the Regulatory Horizons Council (RHC) produces excellent, expert work, but it has few levers to ensure its recommendations are taken forward. This means its work can often be overtaken by other issues that may be more urgent, but no more important. Instead, reports should get a response from the government within 1 month, not merely 3-6 months as the government committed to in its response to the Vallance/McClean Pro-Innovation Regulation of Technologies Review. The RHC should also be able to fund the next phase of work to accelerate progress, such as via control of the Regulatory Pioneers Fund. We would also endorse integrating the RHC and RPF into the new Regulatory Innovation unit.

Additionally, the Digital Regulation Cooperation Forum – a dedicated effort to share insight and resources between ‘digital’ regulators – should be expanded into a broader Technology Regulation Cooperation Forum (TRCF). Currently, the DRCF membership only includes Ofcom, the CMA, the FCA and the ICO, and while this narrow focus is effective it’s nevertheless a model that should be expanded more widely. These 4 regulators – together with the MHRA, the Civil Aviation Authority, the Vehicle Certification Agency and many other regulators at the frontier of AI and other technologies – would benefit from improved cooperation to accelerate understanding of new technologies and business models.

For example, generative AI that continuously improves and evolves is a poor fit for traditional regulatory processes, in multiple sectors, which focus on authorising discrete products and services at one point in time: contrast a static x-ray machine with a continuously iterating AI medical device. The MHRA, however, has already developed world-leading guidance on this issue for AI medical devices. It’s a framework that autonomous vehicle regulators are already exploring how to adapt, and other regulators may be similarly keen to adopt and fork it for their own use cases.

Exploring a cross-sectoral innovation regulator

Finally, as frontier, disruptive innovations also challenge legacy, sectoral regulator structures, entirely new regulatory models should be considered. Startups who cross multiple regimes still face high and often duplicative costs early on, while others fall through the cracks of existing regulatory perimeters.

Cross-sectoral sandboxes are one way to solve this, and the announcement of a new suite following the Vallance/McClean Review – including for AI, space, engineering biology and energy – are a positive sign of intent. But sandboxes have also historically faced challenges. Without i) stable funding, ii) a clear pathway for firms to full authorisation, and iii) sufficient freedoms within the sandbox environment for firms to gather evidence necessary to achieve other commercial, regulatory or fundraising milestones, sandboxes can simply become marginalised units within regulators that provide little durable value. This means some have failed altogether, while others (such as the FCA’s fintech sandbox) have struggled to sustain their impact or engender a more widespread, pro-innovation regulatory culture. At minimum, the government must beware the same drop-off in intensity repeating.

More ambitiously, however, the government should consider a new, permanent, cross-sectoral innovation regulator with an explicit mandate to support innovation. This would have a fundamentally different incentive structure and risk appetite compared to today’s sectoral regulators. It would prioritise innovation rather than marginalising it, as authorities that juggle multiple duties and objectives within a single narrow sector end up doing. As argued by John Fingleton (UKRI board member, Form adviser, and former Head of the predecessor to the CMA), this new entity could have a better risk appetite and incentive structure by operating akin to consolidated pension funds: risk appetite could be pooled from existing regulators, and the bigger its portfolio, the more it can afford to take risks.

Fortunately, there is a precedent here. Accelerate Estonia is a dedicated unit in the Estonian Ministry for Economic Affairs which exists to identify and enable scalable, novel technologies with significant economic potential that are held back by existing rules. As a central unit, they hold both the mandate over other departments to remove regulatory barriers and have the capacity to do the heavy lifting for them, with most projects completed in less than a year. This provides a blueprint for an institutional design which is proven to be effective, and one that the UK should build on quickly.

We’ll be continuing our work to fix the regulators and we’re always keen to hear from founders, investors and policy folk working in regulated markets. If you’re fundraising, have feedback about the report, or want to share an experience with a regulator, get in touch.

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Startups and investors have long campaigned for policy changes to improve access to capital and talent, two of the critical ingredients for any tech ecosystem. But we’ve lost track of the third ingredient: access to customers. Over-stretched regulators now stand between an ever-growing number of UK startups and their users. For many this is now their biggest barrier to growth.

Unlike capital and talent, there’s been little focus on the backlogs and bottlenecks at the UK’s regulators. And today, in the post-Brexit, AI era, we are particularly exposed: regulators are left unable and under-equipped to carry out both their existing and future duties.

Progress in AI, bio, food, health, finance, transport and many other sectors is core to the UK’s economic growth. But while entrepreneurs in the ‘markets that matter’ are holding up their end of the bargain, regulators are increasingly unable to move as quickly as the public interest demands.

This change has crept up on the UK over the decade since politicians, regulators and entrepreneurs combined behind the ambition to make it the “fintech capital of the world”. This compact worked, delivering a group of globally-leading companies and putting the UK second only to the US in terms of the vibrancy of its startup ecosystem.

Yet ten years on, this spirit of innovation and regulatory capacity has stalled. We cannot compete with the US on market size or government subsidies. But we can become the best place for startups to design, test and bring innovation to market, in partnership with regulators.

Singapore and the US are already tempting UK cultivated meat companies to relocate, not least because they have moved more quickly to regulate and provide innovators with an efficient, quality authorisation service.

A similar story is playing out in almost every other sector where UK entrepreneurs and policymakers should be partnering in the public interest. Medical device and biotech startups battle MHRA delays daily, fintech startups regularly face backlogs at the FCA, while AI companies wait nervously for regulators with limited capacity or technical expertise to take on new powers.

Getting back on track

Regulators need three things to get this right: resources, rules and ambition.

Some have the ambition and the right legislative rules but lack the resources. When demand for doing the day job grows — particularly as they took on new duties post-Brexit — space for enabling innovation gets squeezed out. The Food Standards Agency stands ready to drive home the benefits of recent changes to the law around genetic editing, but can’t find the cash to deliver a new novel foods system (read our recent interview with the CEO, Emily Miles). 

These regulators need funding that matches the importance of their role in enabling innovation. Even tens of millions more per year would be a tiny fraction of the wider government science budget. And this isn’t just about core staffing — pay bands hold regulators back from hiring appropriate technical talent and rewarding internal efforts to accelerate innovation. Here, food and AI startups will find common cause.

Other regulators are constrained by the rules they operate within, even if they have the resources and ambition to drive innovation. As we discussed with Alex Kendall, Wayve CEO, the various road safety authorities cannot push on with autonomous vehicles without a change in the law. But even deregulation requires investment: both of scarce ministerial and parliamentary time (which has continually held back the Transport Bill) and of regulatory capacity to design and implement new systems once the law changes, as we’ve seen with gene editing.

A final group, including the FCA, lack the ambition and incentives to prioritise innovation next to their primary duty to protect consumers, even where they have the resources and legislative flexibility. So instead of fast-tracking its backlog of startup applicants, it is pressuring some to “voluntarily” withdraw. This short term conservatism not only comes at the expense of the UK’s chance to build the next generation of great fintech companies, but also the long term benefits that competition and innovation generate for consumers.

These regulators need political instruction to prioritise innovation and political cover to take risks. Greater use of periodic steers from Ministers is one way forward. We also need to hold regulators to account, both through Parliamentary scrutiny and new data, to measure both performance and the costs of foregone innovation.

Green shoots

Fortunately there is momentum. New consultations from the government and the House of Lords are digging into the state of UK regulators. The review into pro-innovation regulation started by Sir Patrick Vallance, and picked up by Dame Angela McLean, will publish its final recommendations soon. The Harrington Review, which searched for answers on inward investment, will have something to say on wider questions of how we make the UK as attractive as possible.

But these initiatives need to include a whatever-it-takes commitment to plug funding gaps and fix the regulators. The Frontier AI Taskforce is a case in point. Its £100m budget took the resource question off the table, while bringing in Ian Hogarth and Matt Clifford anchored its commitment to attracting expertise from the tech sector itself. This approach should be the norm not the exception.

For all the hand-wringing about the UK’s industrial strategy or its response to the US Inflation Reduction Act, it is regulatory agility and ambition that can make the biggest difference to our economic outlook. It is time to take that opportunity seriously.

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