Deposit Management Organisation (DMO): application form guidance

On 10 July 2025, the Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs, Huw Irranca-Davies, set out the next steps for delivering a Deposit Return Scheme (DRS) for Wales.

The announcement follows extensive engagement with stakeholders across the drinks industry, retail, materials sectors, environmental organisations, and UK and devolved governments. It reaffirms Wales’ commitment to a DRS that delivers tangible benefits for the nation while ensuring interoperability with the rest of the UK.

Wales will accelerate its implementation timetable to align with the UK‑wide rollout in October 2027, reducing operational complexity and costs. Crucially, glass will remain in scope for the Welsh scheme, enabling Wales to lead the way in embedding reuse as a core element from the outset.

With a proud record as second in the world at recycling, Wales is uniquely positioned to build on this success and move beyond recycling towards a circular economy. The Welsh DRS will complement existing efforts by households, businesses, and local authorities, drawing on global best practice where reuse is already delivering real-world benefits.

The Deposit Management Organisation (DMO) will work with Welsh Government and industry to deliver a scheme that is ambitious, practical, and future-proofed – supporting small businesses, tackling litter (including broken glass, which remains a significant safety concern), and unlocking economic, social, and environmental gains.

This approach cements Wales’ leadership in sustainability and ensures that the DRS contributes to “Deliver a Best for Wales” model, fostering wellbeing and resource efficiency as part of the nation’s transition to a circular economy.

Huw Irranca-Davies MS
Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs

1.1 This document outlines the necessary information to demonstrate that the applicant is qualified for the position of designated DMO, meeting the Welsh Government approval criteria, and to the satisfaction of the Welsh Government’s Ministers.

1.2 A guidance document has also been developed that should be reviewed in conjunction with the completion of this form.

1.3 This document consists of 4 sections, and all required information must be fully completed prior to the submission of the finalised form.

1.4 A submitted application must include the following:

• All information specified in Section B.
• All information specified in Section C.
• All information specified in Section D.
• All information specified in Section E.

2.1 Across Wales, consumers purchase an estimated 1.45 billion single-use drinks containers each year, comprising 0.55 billion PET plastic drinks bottles, 0.65 billion drinks cans, and 0.25 billion glass bottles.

Keep Wales Tidy surveys found high levels of drinks-related litter. present on 43.6% of streets, with levels in individual counties ranging considerably from 19.4% of streets to 86.1%. As well as posing a risk to people, pets and wildlife, litter is expensive to clean up and reduces the attractiveness of our communities.

The occurrence of glass bottles on Wales’s streets has more than doubled in the last four years (now at 5.2%) with 3.6% of streets having broken glass bottles and 1.7% of streets having enough broken glass to represent a distinct hazard [Local Environmental Audit and Management System (LEAMS) 24/25].

2.2 A DRS is a system which adds a small deposit to a drinks container at point of sale which is then redeemable when the container is returned. This is most commonly either to an over-the counter point or to a reverse vending machine (RVM), although a world first digital DRS trial has been undertaken in Wales as part of this work as it could enable deposits to be redeemed at home, with items returned via kerbside recycling.

2.3 Ultimately a DRS is simply a mechanism to facilitate the collection of the drinks containers (via a redeemable deposit) which can then either be recycled, or in the world’s best schemes, reused. The latter being by far the most sustainable and cost-effective option.

2.4 As well as supporting recycling and reuse, by feeding the containers or recyclate back into the economy, the scheme supports the decarbonisation of those industries and in parallel has also been demonstrated by international schemes as being effective in preventing the littering from the on-the-go consumption of products.

2.5 The introduction of a DRS in Wales will encourage a shift away from a throwaway culture by placing a monetary value on empty drink containers. DRSs are also an internationally proven method of recycling and reusing drink containers.

2.6 A DRS will enhance the availability of high‑quality recyclable materials and promote the circularity of drink containers thereby creating a closed-loop recycling system for bottles and cans.

2.7 In addition to improving the quality and quantity of recyclate, a DRS has also proven to reduce litter in communities and redirects the material away from residual waste systems.
2.8 In line with the broader policies set out in the Welsh Government’s strategy, Beyond Recycling, the DRS is a key step in our commitment to moving towards a more circular economy which keeps resources and materials in use for as long as possible and avoids all waste.

2.9 The scheme will provide the opportunity for increased green growth within Wales, including green jobs for Welsh citizens.

2.10 The DRS will help support the transition to reuse for all drinks containers, including those made from glass.

3.1 The DMO for Wales will function as scheme administrator for the DRS.

3.2 The Deposit Return Scheme regulation for Wales does not establish the DMO as a statutory body; instead, it will assign functions to a legal entity appointed by the relevant Welsh Government Ministers.

3.3 There is no prohibition on the entity carrying out other functions aside from its DMO functions, but as a matter of practicality it is likely that applicants may establish a company or other entity whose sole purpose is to fulfil the functions of the DMO.

3.4 As set out in the regulations, the DMO should be an independent, not-for-profit private organisation that is responsible for the overall administrative operations of the DRS in Wales. This includes the management and oversight of the material and financial transactions within the framework of the scheme.

3.5 Recognising the presence of existing DMOs across the UK, it is essential that the schemes are designed to be as interoperable as possible. We encourage the applicant to adopt a governance and operational structure that reflects this principle and clearly demonstrates how interoperability with other UK schemes will be achieved.

Specifically, the applicant must set out proposals to:

• Ensure effective cooperation with other DMOs operating DRS’ in the UK.
• Facilitate the return of in-scope containers purchased in one part of the UK in another, enabling a seamless experience for consumers.

3.6 Support the registration of producers and importers of in-scope containers for the UK market, ensuring consistency and efficiency across borders.

3.7 As a not-for-profit organisation, the DMO is mandated to use its funds solely for its objectives and cannot distribute income, capital and dividends to members, directors, or officers.

3.8 We require that the DMO will be accountable for achieving the collection targets as referenced in the DRS for Wales Statutory Instrument for the materials in scope of the DRS.

3.9 Natural Resources Wales (NRW) will be the regulator for the DMO in Wales and will manage the DMO’s compliance of the Welsh DRS regulations, the DMO’s conditions of appointment and Operational Plan.

3.10 A draft Operational Plan must be submitted TSW. As the regulator and in accordance with the regulations, NRW will be tasked with taking enforcement action in instances where the DMO fails to comply with its Operational Plan.

4.1 The applicant must complete the following section as part of the application.

4.2 An applicant may decide to apply as a group of bodies corporate. This could include one or more service companies providing IT systems or collection services to the DMO.

Name of organisation (including any business names)

Registered or main office address and postcode

Address for service (if different from above)

Email address

Contact number

Company registration number (if applicable)

VAT registration number (if relevant and available)

Contact name

Job title

Notification preference (please choose at least one) Email / Post

4.3 Should the applicant decide to apply as a group, they must set out how the group will be structured, specifying which entity is proposed as the DMO and which services will be supported by other group members.

5.1 The DMO must be in existence on the date the application is submitted to us. The information provided should set out clearly the nature of the entity that the applicant is proposing will fulfil the DMO role. The internal governance of the DMO is key to ensuring the organisation functions effectively and remains accountable to its members. Any founding documents which provide information to this effect should be submitted as part of the application.

5.2 The applicant needs to set out how the governance of the DMO would be structured, including but not limited to the following:

• the role of the board and leadership team, including initial membership details of these persons (i.e. name of member, name of the company/trade body/etc they are representing or to which they belong)
• reporting mechanisms and decision-making processes including voting rights.

5.3 Detail is also needed on decision making within the organisation, covering how key commercial and financial decisions will be made, how risk will be managed and how accountability, oversight and supervision will be used to ensure successful procurement and implementation.

5.4 Information is also welcome regarding the expertise brought into the DMO via the proposed senior leadership team, knowledge transfer from industry and international best practice.

5.5 When submitting the application, the following documentation is required:

• details of membership
• copies of any shareholder/member agreements
• details of senior management and evidence of suitability for the role
• articles and memorandum of association, or other documents forming it, if not a limited company
• confirmation by reference to the relevant constitutional documents that the DMO is a not-for-profit body and not a charity and will remain so.

5.6 In addition, the following must also be provided when submitting the application:

• The applicant is required to demonstrate that they have broad, cross-industry support for being appointed as DMO, particularly from scheme producers and scheme suppliers, given the role the DMO plays in operating the scheme on behalf of these sectors. Support should come from as broad a range of industry as possible, including both small and large producers and retailers, manufacturers, importers and fillers, wholesalers and trade organisations.
• A proposed strategy which ensures views from all scheme producers and suppliers, and of consumers are obtained and considered in carrying out DMO functions.
• The purpose for which the DMO applicant intends to use any financial amounts it can retain under the regulations that are not required to finance the DRS.

5.7 The applicant must also confirm that none of the grounds for revocation of the DMO’s appointment apply to any DMO applicant or any group members, including any connected persons of that DMO applicant. The applicant must provide details of the due diligence undertaken to provide that confirmation.

5.8 The applicant is asked to provide information on the contracts and agreements it intends to put in place with relevant businesses, namely producers and those operating return points. This should capture information such as reporting requirements, payment terms, data protection/usage, and any additional pre‑requisites or conditions beyond the regulations. Heads of terms are acceptable. The following must also be submitted, but can be submitted in draft form:

• A clear plan for the establishment and mobilisation of the DMO structure.
• Governance and decision-making processes and responsibilities.
• The contracts or agreements proposed to enter into with scheme producers, scheme suppliers, scheme retailers, take-back scheme operators and return point operators.

5.9 If the applicant is a group, confirmation of the following is also required:

• A full explanation of the structure of the group, together with a clear plan explaining how, and when, the group will be established and mobilised.
• Details of the intra-group arrangements proposed between the various members of any group, including how those arrangements will ensure that the DMO applicant pays only reasonable remuneration for goods or services supplied.

6.1 The applicant must submit an Operational Plan which clearly demonstrates how the scheme is to be delivered along with how it intends to achieve the collection targets in Wales, its intended benefits for the environment, circular economy and industry, and describe how it aims to mitigate potential impacts on consumers and businesses.

6.2 To ensure the plan is in line with the legal responsibilities, the successful DMO applicant should review the Welsh DRS regulations along with the guidance set out in the Operational Plan guidance document.

7.1 Ensuring the circularity of in-scope drink containers is a core requirement of the DRS in Wales. In line with the Well-being of Future Generations Act, the DMO must also demonstrate how the scheme will be designed and operated to be future‑proof, adaptable, and resilient to evolving environmental, technological, and market conditions.

7.2 The applicant must provide clear evidence of how it will:

• Collaborate with industry to future-proof the scheme, including through the adoption and promotion of innovative practices and technologies.
• Establish a credible and scalable pathway to reuse, ensuring that collected drink containers are reused where appropriate and feasible.
• Implement the requirement for producers to have first refusal on material returned for recycling, supporting closed-loop systems and high-quality material recovery.
• Operate a scheme in line with final legislative requirements. Subject to the legislation being made.
• Provide robust evidence of litter reduction outcomes as a direct result of the DRS, including through monitoring, reporting, and evaluation mechanisms.

7.3 The DMO must also implement a DRS that actively supports innovation in litter reduction, ensuring that in‑scope containers are captured through multiple, complementary mechanisms beyond traditional return points.

This includes, but is not limited to:

• Encouraging the development and integration of new technologies or approaches that enhance container recovery in public spaces and hard-to-reach areas.
• Driving strategic collaborations with the third sector, local authorities, community groups, and innovators to collect data, design, pilot, and scale alternative collection models that influence and embed new behaviours.
• Proactively adapting the scheme in response to shifting consumer behaviours and littering patterns, ensuring it remains effective in promoting long-term behavioural change and delivering measurable environmental and social benefits.

8.1 To be registered with the scheme, producers need to understand how long the registration process will take, how the process is interoperable with the other UK schemes, and the expected frequency of reporting in-scope containers placed on the market. Therefore, we need to understand the applicant’s plan for registering producers with the scheme. A DMO may charge a producer fee to registered producers, which can only be used to cover the DMO’s administrative costs for the DRS and the cost of NRW and local authority trading standards teams regulatory functions.

8.2 The applicant must provide evidence of the following:

• The proposed method for registering new producers with the Welsh DRS, the ongoing management of the registration list including publishing the register and removing producers who are no longer participating in the scheme.
• The information the applicant expects from scheme producers, and how they will facilitate producers’ registration and reporting of required data, such as container details and placed on market values.
• Any contracts or agreements and processes (in head of terms form where necessary) the DMO will need to enter into with producers.
• Details of the factors the applicant will consider in deciding whether to charge registration fees.
• Information on the process for regularly reviewing the registration fee, with the comprehensive review conducted annually clarity on how producers will pay the registration fee.

9.1 Additional fees must be charged on a ‘per‑container’ basis and proportionate to what a producer places on the market. There should be no cross-subsidisation between materials
and/or between schemes within the UK. All relevant projections or estimates must be provided, and details of how fees have been calculated must be shared with registered producers.

9.2 Applicants must provide:

• in accordance with the regulations, the intended approach to calculating, reviewing, revising and collecting producer fees per container
• consultation plans on producer fees per container
• information on the process for regularly reviewing the per container fee, with the comprehensive review conducted annually.

10.1 The DMO will be responsible for establishing, implementing, and managing the return point network across Wales. This includes:

• Creating and maintaining a register of return point operators and DMO return points.
• Assessing and determining applications for exemptions from mandatory return point obligations.
• Reviewing and approving applications for voluntary return points.
• Operating its own return points where necessary, including – but not limited to – local sorting centres: or local return hubs and other supporting infrastructure.

10.2 The DMO must be responsible for establishing, operating, and regularly reviewing the return point network across Wales. This includes ensuring the network is accessible, efficient, and responsive to the needs of all communities – particularly in rural and hard‑to‑reach areas.

10.3 The DMO must also work in partnership with local authorities to support the effective operation, and integration of return points within existing waste and recycling infrastructure, and to ensure alignment with local service delivery and community needs. Consideration should also be given to existing kerbside collections systems. Further details can be found at section 16 Collections and Logistics.

10.4 The applicant must provide detailed information on the following:

• How the DMO will regularly review the number, location, and accessibility of return points, with particular consideration for rural and underserved areas.
• The contracts or agreements the DMO will enter into with retailers, obligated entities, and return point operators, including arrangements for registration and data submission.
• The process for reviewing and determining applications for exemptions from mandatory return point obligations, including timelines, criteria, and decision-making procedures.
• The process for scheme suppliers to apply for, and for the DMO to authorise, voluntary return points.
• How the DMO will monitor and evaluate the performance of the return point network, including mechanisms for continuous improvement.
• Any draft or indicative contracts or heads of terms the DMO will use in agreements with retailers and return point operators.
• The procedure for revoking a return point operator’s registration where necessary, including grounds for revocation and appeal mechanisms.

11.1 To ensure broad consumer access and convenience Scheme retailers should establish and operate take back services that facilitate the collection of in-scope containers from consumers’ homes that enables the return of in-scope containers outside of physical return points.

11.2 The applicant must therefore supply the following:

• Details on the proposed approach to registering take back services offered to consumers by scheme retailers.
• Details on the proposed approach to collecting or accepting the return of in-scope containers from take back service providers.
• Clarity on how the applicant will make payments to take back service providers for the in-scope containers it collects or accepts from them.
• Demonstrate a clear plan for their phased introduction and integration into the wider return network.
• A proposed timeline and approach for registering take-back services offered by scheme retailers, including online and home collection models.
• A process for collecting or accepting in-scope containers from registered take-back service providers, ensuring traceability, compliance, and alignment with scheme objectives.
• A transparent mechanism for calculating and issuing payments to take-back service providers for the containers collected or returned, including how service quality and performance will be monitored.
• An outline of how the applicant will support and encourage the development of take-back services over time, particularly to improve accessibility for consumers who may face barriers to using physical return points.
• This approach must ensure that take-back services are scalable, inclusive, and aligned with the long-term goals of the scheme.

12.1 The applicant must indicate their preferred deposit level (or deposit levels), with deposit level(s) setting being consistent, evidence based, and minimising challenges around interoperability with other UK schemes. The deposit level(s) should be reflected in the applicant’s business plan and financial forecasts. Additionally, the applicant should also have plans on how it will receive payments of deposits collected by scheme suppliers.

12.2 For this, the applicant should provide the following:

• The proposed approach to setting the deposit level(s).
• Consultation plans on the deposit level(s).
• The proposed approach to setting, reviewing, revising and publicising the deposit level(s).
• The types of data and evidence the applicant will draw upon in setting the deposit level(s).
• The proposed approach to collecting deposits from scheme suppliers.
• Details about how the applicant will communicate to scheme suppliers the amount they must pay, the dates for payments, and the accepted payment methods.
• Information on how the applicant will work with NRW in cases of non‑payment.

13.1 To cover the costs of the return point service, all return point operators (including grocery retailers and voluntary return points) must be paid a handling fee by the DMO.

13.2 To ensure the financial sustainability of the return point network, all return point operators – including grocery retailers, voluntary return points, and where applicable, local authorities – must receive a handling fee from the DMO to cover the costs of providing return services.

13.3 The applicant must provide a comprehensive approach that includes:

• A clear methodology for calculating handling payments, with specific consideration for the needs and cost structures of small retailers and community-based return points.
• Consultation plans to engage with retailers, local authorities, and other stakeholders on the design and fairness of the handling fee structure.
• The proposed payment process, including frequency, verification mechanisms, and how disputes or adjustments will be managed.
• Indicative handling fee levels, including any proposed variations based on return point type, location (e.g. rural vs urban), or volume handled.
• An explanation of how local authorities could be supported or incentivised to operate return points – particularly in areas where retail coverage is limited or where public infrastructure could enhance accessibility.

13.4 This approach must ensure that handling payments are transparent, equitable, and sufficient to support a diverse and resilient return point network across Wales.

14.1 When the Welsh DRS is operational, the DMO must publish a scheme logo (plus an optional packaging logo for drinks sold in multipacks). To ensure interoperability, the DMO must agree a common approach to logos and return codes with the other UK schemes.

14.2 The applicant must provide the following:

• the proposed approach to setting a scheme logo (and any optional packaging logos)
• the proposed approach to scheme return codes
• the proposed approach to setting consistent scheme logos, scheme packaging logos and return code requirements across the UK.

15.1 The DMO will oversee deposit flows ensuring consumers receive refunds when they return containers. It will then reimburse scheme return point operators and for the deposits refunded to consumers.

15.2 The applicant must provide the following:

• proposed approach to reimbursing for refunds they have paid out to consumers
• information on how reconciliation will work with other schemes across the UK
• outline the process for return point operators to administer the charitable donation of consumer deposits, for both local and national charitable causes.

16.1 The DMO will be responsible for collecting all returned in-scope containers from:

• registered return point operators
• on-sale or mixed retail premises
• take back service providers.

16.2 To ensure an efficient, equitable, and environmentally responsible collection system, the applicant must provide a detailed approach for implementing and managing collections and logistics through a comprehensive collection framework.

This framework must include:

• The proposed frequency of collections, including how this will vary by location, return point type, and volume.
• The methods for sorting and transporting materials, ensuring high-quality recycling and reuse outcomes.
• A clear strategy for servicing rural and remote areas of Wales, including how service equity will be maintained.
• Consideration of how Welsh publicly owned assets and services – including those operated by local authorities – could be utilised to support or deliver collection and logistics functions.
• Opportunities for partnerships with local authorities to enhance efficiency, reduce duplication, and align with existing waste and recycling infrastructure.
• How the DMO will ensure transparency, accountability, and performance monitoring across the collection network.

16.3 The approach must demonstrate how the logistics system will be resilient, scalable, and aligned with Wales’s environmental and circular economy goals, while also delivering value for money and supporting local service delivery.

17.1 There are other regulations within Wales and the UK that the DMO will need to take into consideration.

17.2 The applicant will need to evidence how:

• They will comply with the Welsh Language and Education (Wales) Act 2025 for operation within Wales and provision of communications for scheme suppliers.
• They have considered its operation in support of the Public Health (Minimum Price for Alcohol) (Wales) Act 2018.
• They will comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
• They will comply with all relevant waste legislation including but not limited to The Environmental Permitting (England and Wales) Regulations 2016 and The Duty of Care Regulations 1991.

18.1 NRW is the environmental regulator responsible for regulating the DMO in Wales.

18.2 Local authority trading standards services are responsible for enforcing laws that regulate how goods and services are sold, rented or hired to consumers, and provide support to businesses to ensure compliance with legal obligations and conduct inspections to monitor compliance.

18.3 The DMO must make payments to NRW to meet the costs incurred in undertaking its functions under the regulations. The DMO must also enter into arrangements with NRW, and local authority trading standards services where applicable, to ensure appropriate access to any information needed to allow the authority to undertake their functions under the regulations.

18.4 The applicant must provide:

• A detailed plan on how the applicant intends to meet NRW’s and local authority trading standards services costs and ensure these are met out of the DRS, through the registration fee, unredeemed deposits, or selling recyclable materials to producers.
• A detailed plan on how it will provide regulators with access to the data required for them to undertake their duties.

19.1 As set out in the draft The Deposit Scheme for Drinks Containers (Wales) Regulations 2026 Welsh regulations the DRS in Wales is due to go live on 1 October 2027 date, as such the following information from the applicant is required:

• A timeline of activity from appointment until the DRS in Wales is fully operational.
• The communication and engagement strategy to support business and consumer readiness.

19.2 The applicant is also required to publish template documents for:

(a) the Scheme information referred to in regulation 28(8)
(b) the RLVP information referred to in regulation 29
(c) the opt-out information referred to in regulation 31(3)
(d) the information referred to in regulation 38 for groceries retailers to provide at or on retail premises without a return point
(e) the information to be provided at a return point as set out in regulation 41
(f) the take-back service information set out in regulation 43(6).
Additionally, the applicant must review relevant decisions in accordance to Regulation 80.

20.1 The applicant must submit a credible, viable and deliverable Business Plan. The applicant must complete the supporting Business Plan template with key financial inputs and assumptions populated in the required fields. The applicant can include supplementary details as necessary with backing calculations to ensure a comprehensive submission.

20.2 The Business Plan and supporting information must provide:

• details of the proposed mechanism for the allocation of any central overheads to the DMO, where the applicant proposes a group of companies to deliver the DRS in Wales
• how those overheads will be allocated to the Welsh DRS
• details of what analysis has been used to verify the estimates underpinning the Business Plan (e.g. industry and scheme benchmarking, engagement with supply chain to inform revenue and cost estimates)
• details of the level of upfront investment that will be required to support the set-up of the DMO prior to the scheme launch date and how those estimates have been reached
• details of proposed working capital, minimum liquidity levels and any overdrafts or other short-term loan facilities that are proposed to manage working capital fluctuations, particularly during the period from the scheme launch date until the scheme supplier starts to receive payments of deposits
• details of the proposed build-up of the reserve fund required by the Welsh DRS Regulations
• details of the proposed levels of risk and contingency included in the forecasts to deal with downside scenarios
• details of any scenario/sensitivity analysis that has been completed on the Business Plan to test downside scenarios.

21.1 Alongside a business plan, the applicant is expected to provide a register setting out their understanding of key financial risks, their approach to managing ongoing financial risks and their proposed mitigations.

21.2 The applicant must provide:

• a register with a concise description of all the major financial risks to the DMO (excluding fraud at this point as fraud is covered later in Section E), and how the applicant expects that they will be mitigated, in alignment with the downside scenarios in the Business Plan
• an overview of the applicant’s proposed approach to managing financial risks on an ongoing basis.

22.1 To protect against financial losses, the applicant must submit evidence of:

• proposals for future corporate insurance policy arrangements including desired terms and plans to obtain these
• any existing corporate insurance policies including provider details and policy terms (including policy limits).

22.2 The applicant must provide any details of its initial proposals or current plans, if these have been formulated, in respect of tax (including VAT).

23.1 The applicant must provide details of its proposed financing plan and how this represents a credible, viable and deliverable plan to secure sufficient financing upfront and on an ongoing basis.

23.2 The applicant must provide the following:

• a breakdown of the proposed sources and uses of capital/financing
• the expected drawdown and repayment profile for each source
• details of the expected interest rates and costs associated with the capital/financing (including expected rates and fees).

24.1 The applicant must provide all of the following:

• Details of the proposed providers of capital/financing and the form that this will be provided in (e.g. capital or loans from entities that ultimately own or control the applicant, or third-party loans).
• Details of the proposed terms of that capital/financing, in heads of terms format as appropriate.
• Evidence that the capital/financing is provided on market terms or, in the case of capital/financing provided by related parties of the applicant, on terms that do not provide for the distribution of income of the applicant to its members, directors or officers, except as reasonable remuneration for the financial facilities supplied.
• Details of the proposed security arrangements applicable in respect of the proposed capital/financing.
• Details of the status of the proposed financing arrangements, including provision of any third-party evidence regarding current commitments.
• Details of all sources of contingent financial support (such as parent company guarantees or contingent facilities).
• If relevant (i.e. previously existing), copies of the audited financial statements for the past two financial years of any providers of capital, financing or contingent financial support from entities that are within the applicant’s wider group structure.
• Expected steps and timeline for securing the capital/financing with drawdowns aligned to the timeline provided in response to Section C 19, so that the applicant can access the funding it requires to establish and operate the DRS in Wales.

24.2 Should the applicant’s costs of establishing the DMO prove greater than anticipated, the applicant must also provide confirmation that the capital/financing or other contingent financial support available to the DMO is sufficient to provide a reasonable contingency.

25.1 In line with The Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011, the applicant must submit information regarding how equality of access will be managed in the scheme.

25.2 This should include detail on:

• How DMO communications will be issued in different languages and formats (e.g. minority languages and audio format).
• How accessibility considerations will be captured in guidance provided to return point operators. For example:

-Wheelchair access to reverse vending machines and/or kiosks containing return points.
-The provision of manual returns support for those unable to access main return points.
-Welsh language and minority languages spoken in Wales, as well as audio format or braille.

• How the applicant will consider and/or encourage the collection and return of in-scope containers for consumers with accessibility requirements.
• Plans for consultation with stakeholders regarding accessibility to the DRS.

26.1 To support the effective operation of the DRS in Wales, digital solutions will need to be developed and implemented. These solutions will need to facilitate registration, reporting, invoicing and payment requirements for DRS producers and collectors. Systems will also need to enable data and information flows across the collection and logistics operation.

26.2 Given the requirements for interoperability across the UK, digital solutions will need to be designed with functionality which supports these requirements where necessary.

26.3 The Welsh regulations require exchange of information with NRW to support their enforcement functions (other than in respect of the DMO). This may include data covering contracts, registrations, producer placed-on-market data, waste collection infrastructure, and returns data/collection rates based on material type separated by nation.

26.4 The applicant must provide information as to how they intend to design, build, implement and test the DRS digital solutions to enable delivery and operation of the scheme. This will require many systems to be in place to ensure scheme producers and retailers that are mandatory return point operators are able register before 1 October 2027.

26.5 The applicant must set out how they intend to maintain and further develop the DRS ICT systems after this date.

26.6 The applicant must also outline the intended measures for ensuring the ongoing security of the ICT systems, including mitigations to any perceived risks.

27.1 There are potential fraud and error risks inherent within DRS. Fraud and error can occur at the front-end and back-end of the DRS operation. For example, if a scheme producer is underpaying the deposits on in-scope drink containers or if return point operators make fraudulent refund claims.

27.2 Technology will play a significant role in reducing fraud and error at every point in the system, from registered barcodes placed on in-scope containers, to data capture by reverse vending machines.

27.3 The applicant must provide information on the risks of fraudulent activity in the scheme, as a minimum in relation to the four areas listed below, and what it proposes to do about preventing such activity in collaboration with the regulators, as appropriate.

• sales related fraud
• collection related fraud
• cross-border related fraud
• DMO internal related fraud.

27.4 The applicant may consider including a risk matrix that assesses the seriousness and likelihood of each fraud risk and identifies the preferred mitigation measures in each case.