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Yes, I am comfortable with 20 per cent. That has not been up for discussion as part of the development of the SI. If the Health and Safety Executive believes that 20 per cent is sufficient for it to get the kind of return that it needs, then I am comfortable with that. The point of the extension is that those checks will have to come after completion of the final registration deadline. Is that right, Dan?

I do not anticipate any further extension to the timescales. I suppose that it is not impossible; however, I understand that a lot of resource is currently being arranged in DEFRA to make sure that it is done in the appropriate time. I expect that we will be back at some point to discuss substantive changes to the registration process because, of course, examining that is what the extension is required for.

Obviously, SEPA is the regulator for environmental issues in Scotland and will be for the environmental impact of REACH overall, but the competent authority for the issue of registration is the Health and Safety Executive. That decision was made across the board with the Scottish ministers, the Welsh ministers and so on, so the Health and Safety Executive is the equivalent of SEPA in this, and we have therefore worked closely with it on the issue. Officials are keeping SEPA very closely updated on all these developments, and it is always welcome to give us its feedback.

I do not know whether Dan Merckel might want to say more about the engagement that he has had with SEPA, but it is certainly not the official body on this. However, the convener is indicating that we need to be as short as possible.

Companies have not been involved from the word go simply because the transparency that the RCI seeks to deliver is already being provided by another register in Companies House. Likewise, we are working with the UK Government on the register of overseas entities—there are a number of registers with different names. That work on overseas interests—the point about which is well made—is on-going.

We are talking about a delay, not reform. It is very deliberately not reform, because I want to maintain the integrity of the register and everything that it seeks to achieve. However, I hope that the delay will help, because I recognise the administrative burden that arises from having a number of titles and from the complex structures in which they are held.

I will respond to a couple of points. First, on engagement with the Church of Scotland and other religious bodies, I think I have already said this, but I am happy to reiterate it: that engagement will be on-going. I, my officials and the Registers of Scotland will be involved in that. We are very keen to make the best use of the additional year and to support religious bodies and others through the process. As I have said, we will do that thoroughly. However, I must be clear about the fact that we will not provide legal advice.

On Fiona Hyslop’s point about the charities bill, I have considered that. That is a result of me having sat down with the Church of Scotland and said, “Tell me what you think I can do to make this better.” I went away and considered every option that the church put to me. One of the things that it raised with me was the charities bill, but that is at stage 1. What I can see so far is that it will require the name of the trustees to be registered, but that does not in any way link to the property. Basically, it is that link that the RCI seeks to bridge. We have to make an assessment. We do not want duplication, but we have to consider whether the other register does the same or more than what we are proposing. With the charities bill, my conclusion so far is that it does not, but I have considered the issue.

Yes—absolutely. I hope that the extension that we have suggested will alleviate the burden on the Church of Scotland, other religious denominations and the charitable and third sector, which are caught in the scope of the RCI.

My officials and I have had extensive engagement with the Church of Scotland over months. I have met the Church of Scotland, it has spoken with the First Minister, and officials have gone back and forward to it. It put a series of suggestions to me on how the burden, as it sees it, could be alleviated. For various reasons, none of those suggestions was acceptable. However, I hope that the one-year extension will allow it to spread the burden and the costs. The work will not have to be undertaken in the same time period, which will help it.

There are significant reasons why retaining the Church of Scotland and other religious denominations within the scope of the RCI is really important. I think that the Church of Scotland owns around 6,000 titles in Scotland. That probably makes it one of the largest landowners by title parcel numbers. A lot of its land is still registered in the register of sasines, which dates from the 1600s. Even experienced solicitors can struggle to note title ownership. For all those reasons, it is very important that it is part of the register, but I hope that the provision will ease the pressure on it.

Absolutely. I have been engaged with them—I can speak about that in a moment—but I also commit to continuing to engage with them. I do not want the Church of Scotland or any of our religious bodies to be unduly pressured by the new requirement, but I mentioned that the majority of the Church of Scotland’s 6,000 titles are in the register of sasines. Those are church buildings, glebe land and manses. That shows why the RCI is required, but I am not going to make the church’s compliance more onerous than it needs to be, and I hope that the extra year will help.

We have had considerable engagement with the Church of Scotland. It has been engaged right from the beginning, since the passing of the Land Reform (Scotland) Act 2016. The Registers of Scotland held a session with the Church of Scotland in the immediate aftermath of the passing of the 2021 regulations, in order to test the beta version of the website. The issue was raised at the First Minister’s annual meeting with the Moderator of the General Assembly of the Church of Scotland. I met them very shortly afterwards, and my officials and I wrote to the Church of Scotland in November and December, and again on 17 January. Most recently, I wrote to the church again on 16 February, but I will continue to liaise with it.

There is always back and forth as part of such conversations. I have not had a set written consultation from which I could tell you, “Here are the responses I got from these individuals,” but there has been an on-going conversation. As I have said, I thought that the original one-year period was sufficient. Stakeholders have come to me and said that they have concerns, and I believe that the 12-month extension is the right way to resolve those concerns. For a number of reasons, I have not been able to take forward some of the other suggestions that were put to me.

No, I do not. As I have said, we have had extensive engagement with the Church of Scotland. I wanted to meet the church as early as I could to understand what its concerns were and to hear what its suggestions were. I have thoroughly considered how possible it would be to make amendments to the legislation to give rise to what the church asked for, which in one case was a full exemption, and in the second case was a special streamlined part of the register for the main church organisations, as it was put. None of those would have been acceptable. They would have created loopholes and inconsistency. I think that that would have led to challenges by other organisations, which would have said, “Where is our special exemption? What is the justification for this?” All of that would not be proportionate when we consider the land holding of churches in Scotland.

As I have said, I do not want to unduly pressurise any religious organisation. I hope that the extra year will help churches to spread the costs and the administrative work. In the meantime, my officials and I, and the Registers of Scotland, will be there to help them with that.

The engagement that I have had so far—the quite intense engagement over recent months—has principally been with religious stakeholders. However, I have no doubt that concerns are spread across the charitable and third sector.