Fourth bi-annual Welsh Government REUL Act update: December 2024 to June 2025

The Retained EU Law (Revocation and Reform) Bill received Royal Assent on 29 June 2023 thereby becoming an Act (‘the REUL Act’). The REUL Act gave UK ministers and devolved authorities broad powers to revoke, replace, and reform secondary retained EU law. Section 17 of the REUL Act requires the Secretary of State, after each reporting period (which is every six months to 23 June 2026), to update the assimilated law dashboard and publish and lay before the UK Parliament a report on the revocation and reform of assimilated law (previously known as ‘retained EU law’ at or before the end of 2023).

Following the publication of the UK Government's Assimilated Law Parliamentary Report: December 2025 to June 2025 (‘UK Government’s report’), the Welsh Government are providing the Senedd with this report on statutory instruments (SIs) made under the REUL Act that are relevant to the Senedd for the period between December 2024 and June 2025. 

The UK Government’s report retains the same format as their previous report. As with our previous report, the below follows the same template as the UK Government’s report and over the same time period. This report only covers SIs where Welsh Ministers have consented to the use of concurrent powers under the REUL Act by the UK Government. This is the same approach being taken by the Scottish Government, who’s parliamentary committee publish their report. A link to the Scottish Government’s report can be found here.

Welsh Government have approached REUL powers proportionately and judiciously. We consider using REUL Act powers only where there are clear benefits to Wales. We believe that this policy rightly focuses resource on delivering our own legislative programme and Programme for Government. Between December 2024 and June 2025, the Welsh Government did not identify any benefit to Wales to justify our use of REUL Act powers. Therefore, no SIs were made by Welsh Ministers in respect of the powers under the REUL Act during this period.

The UK Government Report states that between December 2024 and June 2025 the UK Government laid twelve SIs using powers under the REUL Act: 

• The Public Procurement (Revocation) Regulations 2025
• The Retained EU Law (Revocation and Reform) Act 2023 (Consequential Amendments) Regulations 2025
• The Companies Act 2006 (Recognition of Third Country Qualifications and Practical Training) (Amendment) Regulations 2025
• Companies (Directors’ Remuneration and Audit) (Amendment) Regulations 2025
• The Electricity Capacity Mechanism (Amendment) Regulations 2025
• The Energy (Euratom Decisions and Miscellaneous Provisions) (Amendment and Revocation) Regulations 2025
• The New Heavy-Duty Vehicles (Carbon Dioxide Emissions Performance Standards) (Miscellaneous Amendments) Regulations 2025
• The Motor Vehicles (Driving Licences) (Amendment) (No. 2) Regulations 2025
• The Vehicle Drivers (Certificates of Professional Competence) (Amendment) Regulations 2024
• The Airports Slot Allocation (Alleviation of Usage Requirements etc.) Regulations 2025
• The Food and Feed (Regulated Products) (Amendment, Revocation, Consequential and Transitional Provision) Regulations 2025
• Retained EU Law (Revocation and Reform) Act 2023 (Social Security Co-ordination) (Compatibility) Regulations 2025

Nine of the SIs were in wholly reserved areas and as such the UK Government did not seek consent from Welsh Government.

Consent was sought by the UK Government and granted by Welsh Government for the remaining three regulations, which included elements within devolved competence. These three regulations are described in Annex A: The Public Procurement (Revocation) Regulations 2025; Retained EU Law (Revocation and Reform) Act 2023 (Consequential Amendments) Regulations 2025; and The Food and Feed (Regulated Products) (Amendment, Revocation, Consequential and Transitional Provision) Regulations 2025.

The UK Government maintains a Retained EU Law and assimilated law Dashboard, which contains a publicly accessible list of retained EU law and assimilated law. At the time of preparing this report, the Dashboard was last updated on 22 July 2025 and reflects the position as on 17 July 2025. It was updated alongside the publication of the third Assimilated Law Parliamentary Report and remains a resource for tracking the status of assimilated law identified by the UK Government. 

The Assimilated Law Report concludes by commenting on the preservation of Section 4 rights. This is in consequence of the REUL Act’s abolishing of the principle of EU law supremacy (in so far as it still applied as an interpretative rule) and the general principles of EU law as ways to interpret UK law. 

The REUL Act provides powers to codify retained case law, section 4 rights, and other interpretive effects into UK law that would otherwise have ceased to apply at the end of 2023. The Report states since the previous Assimilated Law Parliamentary Report, no further restatements or codifications related to section 4 rights have been required. This is primarily as existing domestic legislation already provides equivalent protection. These restatement powers are available until 23 June 2026.

Liaison between the UK Government and Welsh Government at official level on the use of REUL Act powers has remained positive.  

The REUL Dashboard includes UK legislation which is reserved, has mixed competence or falls under devolved competence. It does not include any legislation made by the devolved governments of Wales, Scotland or Northern Ireland.

The Assimilated Law Report notes that reform of assimilated law will support regulation in line with the UK’s modern Industrial Strategy and the eight sectors identified, the Trade Strategy, the Infrastructure Strategy and the SME Strategy. This is linked to wider commitments for regulatory reform and an Action Plan published by the Chancellor. The Report also cites reform of assimilated law as helping to accelerate Net Zero, regional growth, and boost economic security and resilience.

Reform of assimilated law will be part of that overall approach the UK Government takes to regulatory reform, and we will continue to monitor and report on the use of REUL Act powers in doing so. The Assimilated Law Report sets out plans to reform and revoke assimilated law, with the majority of proposals not aiming to use REUL Act powers, but REUL Act powers still being used for some (e.g. aviation safety, merchant shipping, and other minor changes). 

As the UK Government’s wider plans for regulatory reform crystallise and we understand any implications for Wales we will work with them so potential opportunities and benefits for Wales are maximised and any risks minimised. The UK Government also reiterates in its Assimilated Law Report their commitment to strengthen relationships with the devolved governments and the EU. 

There has been a slight increase in the UK Government’s use of REUL Act powers since our last bi-annual report as the new UK Government’s legislative programme develops. We continue to work closely with UK Government on any proposals which have devolved implications. We do not expect a significant increase in the UK Government’s use of REUL powers before they sunset in June 2026. 

When the UK Government proposes and seeks consent to use concurrent powers, the Welsh Government will consider any requests on a case-by-case basis, in line with our own priorities and the Welsh Government’s Principles on UK Legislation in Devolved Areas. The Welsh Government will keep the Senedd notified in line with agreed protocols and the Senedd’s Standing Orders.

The Welsh Government does not currently have any plans to use REUL Act powers, but this will be kept under continuous review.

Our penultimate bi-annual report is expected in early 2026, following the UK Government’s report. 

Statutory instrument

The Public Procurement (Revocation) Regulations 2025

Detail 

The SI revoked, either in full or in part, five items of procurement legislation that are redundant in England, Wales, and Northern  Ireland, following the commencement of the Procurement Act 2023 on 24 February 2025.

Progress

Laid before the UK Parliament on 25 April 2025, and the Welsh Government’s Written Statement was published on 30 April 2025. The Regulations came into force on 15 May 2025.

Statutory instrument

The Retained EU Law (Revocation and Reform) Act 2023 (Consequential Amendments) Regulations 2025

Detail

Makes the last set of consequential amendments needed to secondary legislation to implement the re-labelling of REUL (and related terms) as “assimilated law” (and related terms) in secondary legislation. 

Also makes provision to remove references in secondary legislation to the general principles of EU law and rights retained under section 4 of the European Union (Withdrawal) Act 2018, which were both removed by the REUL Act.

These codifications aim to enhance legal clarity of the statute book, ultimately increasing the accessibility and comprehensibility of the law. 

Progress

Laid before the UK Parliament on 27 January 2025, and the Welsh Government’s Written Statement was published on 30 January 2025. The Regulations came into force on 27 February 2025.

Statutory instrument

The Food and Feed (Regulated Products) (Amendment, Revocation, Consequential and Transitional Provision) Regulations 2025

Detail

Regulated products are certain food and feed products that require authorisation before they can be sold on the market. The FSA manages regulated product market authorisations in England and Wales. 

The GB wide SI, that came into force on 1 April 2025, amended regulated products legislation concerning feed additives; food additives; food enzymes; food flavourings; food contact materials; food or feed containing, consisting of or produced from genetically modified organisms (GMOs); novel foods; and smoke flavourings.

The SI made two key changes: 
(i) removing statutory requirements for the periodic renewal of authorisations  for three regulated products regimes and 
(ii) allowing authorisations to come into effect following ministerial decision and then be published in an official register or list, rather than being prescribed by secondary legislation.

The SI also revoked legislation containing authorisations of regulated products whilst preserving the authorisations themselves so that they can continue to have effect and be published in the relevant register or list. The SI made consequential amendments to various Scotland, Wales and England statutory instruments and to four assimilated direct legislation instruments.

Progress

Laid before the UK Parliament on 17 March 2025, and the Welsh Government’s Written Statement was published on 30 January 2025. The Regulations came into force on 1 May 2025.