Deposit Return Scheme – assurance of action plan: report – September 2021

3.0 Conclusions of the AAP

3.1 At the previous Review, the DRS programme was awarded a 'Red' delivery confidence, principally because the currently legislated schedule for a July 2022 'go-live' is not achievable. Whilst this legislation remains extant, this Review found that the July 22 target was now dismissed by all parties, and though a revised date had not yet been agreed, there was a universal coalescence and consensus in and around a September 2023 date for go-live. Assuming that this date will be agreed, and that this will be reflected in a revision to legislation, then this Review concludes that delivery confidence assessment for the DRS Programme has progressed from Red, at the last Review, to Amber-Red currently.

3.2 In the short period since the last Review (June 2021), there has been a significant improvement in the clarity for the direction of this Programme. This progress has been achieved through significant cooperation, effort and enthusiasm by the DRS Programme Team, and all wider stakeholders, working constructively to pursue an effective Scheme. The improving but cautious delivery assessment of this Report is reflective of the significant complexities and uncertainty that still remain in the implementation of the DRS and for which resolution is ongoing.

3.3 In addition to formally agreeing a revised go-live date and the critical path to this delivery, and subsequently amending legislation, there remain other significant ongoing issues which proffer significant risk and require continued prompt and cooperative action to bring to a positive resolution. These include, but is not limited to: VAT deposit charge resolution, confirmation of on-line take-back position and, most importantly, Circularity Scotland Limited (CSL) securing [Redacted] subsequent governance-management resource to mature and develop its corporate and operational systems. Singularly, and/or in combination, such issues could quickly bring a September 2023 target into jeopardy if not concluded timeously.

3.4 Positive conclusion of these live, ongoing actions, by the end of 2021, would support a cautious improvement of delivery confidence assessment to Amber, albeit the underlying complexity and many challenges and risks (e.g. the deposit operating system and the ICT system) of the Programme will remain.