The Cunliffe Report: a missed opportunity for meaningful change

21st July 2025

The Independent Water Commission has shared 88 recommendations in its new report, known as the Cunliffe Report, to the English and Welsh governments.

It covers how the freshwater system is regulated and how to manage the competing demands on water. It also looks at how water companies are governed and how critical water infrastructure can be kept resilient both now and in the future.

The review of the water sector should have presented a pivotal moment for our precious freshwater systems but is fundamentally flawed by its lack of ambition.

At Earthwatch Europe, we’ve been advocating for urgent reform. While the Cunliffe report offers some positive steps, it largely falls short of recommending bold, meaningful change needed to create a positive freshwater future.

There is no single, simple change, no matter how radical, that will reset the water sector and restore the trust that has been lost

– Cunliffe Report

Missed opportunities

We were encouraged to see the interim report recognise the need for regional planning tied to local voices, and support for nature-based solutions with wider social and environmental benefits.

The final report builds on this, recommending new, long-term National Water Strategies for England and Wales, published every five years with a 25-year horizon. Earthwatch supports this, particularly emphasising the need to prioritise positive environmental outcomes within these strategies.

The report proposes a comprehensive systems planning framework, with regional water authorities responsible for integrated planning in England. Earthwatch welcomes this as champions of the Catchment Systems Thinking Cooperative (CaSTCo) model and advocating for a national standardised framework delivered at a catchment level.

However, the report contains critical gaps that represent a significant missed opportunity. We highlighted several areas requiring urgent attention and reform in our response to the report’s Call for Evidence, including:

• Prioritising environmental outcomes
• Building climate resilience
• Integrating a collaborative management
• Empowering citizen science
• Strengthening regulation and enforcement
• Reforming economic regulation

While some of these were touched upon, the shortcomings in enforcement capacity and lack of consideration of the role of citizen science are particularly disappointing.

Unified regulation and the power of people

The Commission recommends combining the water functions of existing regulators – Ofwat, the Drinking Water Inspectorate, and the water environment functions of the Environment Agency and Natural England – into one integrated water regulator for England.

This is significant. We at Earthwatch have consistently called for strengthened regulation and enforcement, and we support the emphasis placed on this within the report.

The report rightly points out a deterioration in public confidence regarding environmental regulators’ ability to enforce against non-compliance.

It advises a reformed and strengthened approach to monitoring, utilising digitisation, automation, public transparency, third-party assurance, and intelligence-led inspections.

We are pleased to see the environment is carefully discussed. It was also positive to see the attention given to stronger oversight of pollution from various sources, including water companies, agriculture, and highways.

It considered issues like abstraction and drinking water. This is especially timely after one of the driest springs on record, making discussions on water reuse and rainwater harvesting schemes even more necessary.

Yet, this is where the power of citizen science, like FreshWater Watch and the Great UK WaterBlitz, could have been more robustly championed.

The Environment Agency itself noted in its Call for Evidence response that the WFD Regulations 2017 could be improved by a more flexible approach to monitoring and reporting, including using evidence from citizen science.

At Earthwatch, we echo this statement, and we urged the future legislative framework to maximise the potential of citizen science.

The report’s failure to fully integrate and empower citizen science into new regulations represents a missed opportunity for more comprehensive and effective monitoring.

Data driven change

The Cunliffe Report marks a critical moment for the water sector, acknowledging past failures. But it is not laying a strong enough groundwork for the long-overdue transformation that is truly needed.

While its recognition of systemic reform, regional planning, and strengthened regulation is encouraging, the focus must now shift dramatically from recommendations to decisive action.

The FreshWater Watch programme empowers people globally to monitor the health of their local freshwater environments. Here in the UK, the Great UK WaterBlitz mobilises thousands to collect vital data on water quality in rivers, streams, and ponds.

This isn’t just about collecting data; it’s about fostering a deeper connection to our natural world and creating a powerful, distributed network for environmental monitoring.

These citizen science initiatives can directly address some of the issues raised in the Cunliffe report and help drive the meaningful change that was perhaps not fully embraced:

• Filling the monitoring gaps and enhancing enforcement: With strengthened regulation comes a need for robust monitoring. Citizen science can provide invaluable, localised data at a scale that traditional methods simply cannot achieve. By supporting and integrating programmes like FreshWater Watch and the Great UK WaterBlitz, the new regulator could gain a more comprehensive and real-time understanding of freshwater health across England and Wales. This would address the gap in enforcement capacity.

• Driving “pre-pipe” solutions: The report advises legislative changes to drive a more coherent approach to “pre-pipe” solutions – stopping pollutants and rainwater from entering the system in the first place. Citizen scientists are often the first to notice changes and potential pollution sources in their local areas. Empowering them with the tools and training to identify and report issues can be a powerful “pre-pipe” defence. Earthwatch, through our extensive experience in training and supporting citizen scientists, can help facilitate this crucial connection between communities and regulatory bodies.

• Building climate resilience: The report discusses better water reuse and rainwater harvesting schemes. Citizen science can play a role in identifying areas most in need of such interventions and monitoring their effectiveness. Our programmes can also help to engage communities in understanding and implementing these solutions at a local level.

• Ensuring transparency and accountability: Citizen science fosters public engagement and transparency. When communities are involved in data collection, there’s a greater sense of ownership and accountability. We believe it’s about effective water regulation and data transparency, and citizen science is key to achieving this.

It’s time to push for meaningful change

The Cunliffe report’s recommendations, while a start, feel like a cautious stumble rather than a confident stride towards the transformative change our water systems desperately need.

With citizen science, environmental outcomes, and collaborative governance at the forefront, we still have an opportunity to build a water system that works for people and nature alike.

But this opportunity will be wasted if we don’t push for the full integration of citizen power and a bolder vision for the future of our water.