FOI CAS-325497: no minutes, no licence, just six emails from 2014

A request, and what it asked for

On May 3, 2026, The National Archives published its response to Freedom of Information request CAS-325497, filed under the title “Documentation relating to OPSI.” The request sought the paperwork behind Registry Trust Ltd’s authority to license and commercially redistribute data from the Register of Judgments, Orders and Fines, formerly the Register of County Court Judgments. It named one target directly: minutes from August 2005 said to record a decision on “bulk re-sale” of the Register’s contents.

The request did not ask whether Registry Trust Ltd had done anything wrong. It asked where the document is that says OPSI authorized the arrangement. A record either exists or it does not, and that is the only question on the table.

The thirteen years the authority is supposed to sit in

From 2005 to 2018, oversight of this kind of Crown licensing ran through a defined chain: OPSI itself, the Advisory Panel on Public Sector Information (APPSI), a statutory body set up in 2003 and empowered from 2005 to hear complaints under the Re-use of Public Sector Information Regulations 2005, and the Information Fair Trader Scheme, OPSI’s complaints process, which ran until 2018. APPSI was abolished when the Re-use of Public Sector Information Regulations 2015 took effect on July 18, 2015, handing the complaints role to the Information Commissioner’s Office.

An arrangement running for over a decade under a government body would normally leave a specific kind of file: governance minutes recording the decision, a licensing document naming the licensee, and a complaint file if any dispute arose. That is the shape of paper this request went looking for.

What The National Archives says it searched, and what it found

The response answers each part in turn, and the pattern repeats: “Information not held.” No OPSI Governance Committee minutes exist relating to Registry Trust Ltd or either Register, for any date, including August 2005, and none amending any such decision, because no original decision is held. The response also states that no information is held on the Director of OPSI, an office also known at the time as the Controller of Her Majesty’s Stationery Office, making any determination about RTL’s use of Register data.

No licensing framework or authorisation document naming RTL was found. No determination exists on whether the Register falls under the Re-use of Public Sector Information Regulations 2005 (SI 2005/1515). No complaint or appeal file concerning RTL’s licensing or fees is held.

One thing did surface: six numbered items of correspondence, several with lettered attachments, exchanged between OPSI and the Ministry of Justice between May and November 2014. The Archives logged the outcome as “Request resolved,” noting “some information provided.” Those six emails are that information.

The correspondence, dated

The material reads as a short, dated sequence rather than a case file. In May and June 2014, OPSI and the Ministry of Justice exchanged draft correspondence discussing what the response calls a “business case,” concerning PSI licensing authority for the Department and non-commercial licensing of aggregated data. An email dated October 6, 2014, records a business-case submission. One dated November 11, 2014, contains an OPSI assessment and recommendation on it. A further email dated November 19, 2014, is the last of the six items.

The record states that a proposal was drafted, submitted, and assessed, in that order, over roughly six months. It does not describe what the proposal covered or what the recommendation was.

The redactions, named for what they are

All six items, and the attachments filed with items 01 through 05, carry redactions applied under section 40(2) of the Freedom of Information Act, the exemption covering personal data, here applied to junior members of staff named in the correspondence.

This is a routine, standard exemption. It withholds who wrote or is named in a given line, not the subject of what was discussed. It does not withhold the business case itself, its dates, or its stated purpose. It explains why parts of six emails are illegible. It does not explain why nothing follows them.

Where the trail stops

The response states that The National Archives holds no record of the 2014 business case being concluded with the issuance of any formal authority. After the November 19, 2014, email, the holding is silent.

That is a fact about the archive, not about the world. The business case may have been approved, rejected, or left to lapse outside these papers. What the record supports is narrower: no document reflecting any outcome was found in this search. The file ends in November 2014. Whether the process it describes also ended there is a separate matter, and this response does not settle it.

Four questions that stay questions

Whether any decision, from August 2005 or any later date, formally authorized Registry Trust Ltd to license, bulk-supply, or resell Register data is not established here; no governance minutes recording such a decision were found.

Whether the 2014 business case reached any resolution is not established; no document after November 19, 2014, addresses it.

Whether the Register of Judgments, Orders and Fines was ever formally determined to fall under the 2005 regulations, or their 2015 successor, is not established; no determination was found.

Whether complaint or appeal records about RTL’s licensing survive elsewhere is not settled by this search. The response notes that APPSI kept its own web archive of complaints handled between 2005 and 2015, separate from these holdings and outside this request’s scope.

What a missing file is, and isn’t

Registry Trust Ltd has maintained the Register, on behalf of the Ministry of Justice, since 1985, and remains the only body authorized to run this public database in England and Wales. The Register itself, tracing to the Register of County Court Judgments established in 1852, was reconstituted in its current form on April 6, 2006. None of that operational history is in dispute.

What this FOI response establishes is narrower: The National Archives, searching its own holdings, could not locate the governance minutes, the licensing authorisation, or the regulatory determination that would show how the arrangement was authorized. What it located instead is six unfinished emails from 2014, about a proposal whose ending, if it had one, is not on file here.

An absence of paperwork is not an absence of authority. It is a fact about what one archive found on one search. No later document, complaint record, or public statement resolving these four questions appears in this holding. If one exists, it is not here.