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I've only had a quick look at the consultation docs, but enough to confirm my bias against outcomes focused regulation.

Even the case studies provided don't actually say whether the rules have been broken in the narrow scenario they describe.The descriptions are often in straightforward terms, e.g. "G has no direct responsibility for the advertising that LawCo undertakes but he has become aware that it is providing misleading information about both the services that LawCo offers and the advertised costs.". Not *might* be misleading, the firm *is* providing misleading information.

However, the guidance as to whether the rules have actually been broken is always couched in vague terms: "[G] is *unlikely* to
have failed to meet 8.8 of the Code of Conduct", "However, G *may* fail to meet other standards ... since he knows about the misleading information but does not do anything about it", "It is also *arguable* that he is in breach of revised Principles 4 and 6", etc...

The importance of this is only highlighted by the conclusion in the case study: "In order to meet the required standards, he may have to advise his clients of the inaccuracies in his employer’s advertisements and consider whether he can remain in his employment and still manage to comply with his SRA obligations as a practising solicitor. "

Poor G has to decide all for himself whether he needs to report his own firm to their clients and hand in his notice, all without any firm guidance from the SRA as to whether the rules have actually been broken or not in this very simplistic example. What chance of real people got in real situations?