As a quick recap, although the primary legislation to notify and punish those whose internet connection is repeatedly used to infringe copyright was rushed through the dog end of the Labour government - with Conservative support from the then shadow Culture Secretary Jeremy Hunt - progress has since stalled.
Two Statutory Instruments were expected to flesh-out how the copyright infringement warning letters will be dispatched, paid for and appealed: a so-called Initial Obligations Code and a shorter Cost Sharing Order defining how the cost of scheme will be split between copyright owners and internet service providers.
Two attempts have so-far been made to enact the shorter Cost Sharing Order, but even this relatively simple piece of legislation only got as far as the notification phase, where other EC member states are notified of draft changes to policy potentially affecting cross-border trade [refs: here, and here].
Both times the Order was quietly dropped, and nothing much has been heard since.
In response to a Tweeted question this morning I thought I'd see if my old Westminster contacts still wanted to talk to me.
Two separate sources told me not to expect the remaining secondary legislation this side of the general election.
Assuming a 2015 general election, and factoring-in time to establish the necessary body or bodies to oversee the operation of the notification and appeals systems, it will be 2016 at the very earliest - and possibly 2017 - before the first warning letters go out.
5 days after I posted this, DCMS released minutes [link] outlining their expectations:
"DCMS expects the first letters to be sent in the latter half of 2015"My own sources were clear that the remaining legislation - two statutory instruments (that might possibly, now, be rolled into a single instrument) - were unlikely to go before Parliament until after the 2015 General Election. By my own estimates it will then take around 9 months to establish the systems necessary to get the first letter out, including the crucial appeals process, hence my claim of 2016.
It seems the Department for Media, Culture and Sport (DCMS) thinks it can be done slightly faster, hence their note of optimism in their timetable of back-end of 2015.
So what's the delay?
One source described the copyright provisions in the Digital Economy Act 2010 as "un-implementable".
The legislation rushed through parliament in 2010 - at the behest of copyright lobbyists asserting prompt action was essential to the survival of the creative industries - was bad.
Since then the UK music and film industries have grown despite the gloom in the rest of the economy and 2012 saw an 11% revenue growth for legitimate downloaded media content in the UK despite progress on the Digital Economy Act stalling.