A problem with legislation in general is that it is often very open to interpretation. Especially legislation around fast-moving technology fields. It’s very difficult to write both broadly applicable legislation that requires minimal interpretation. And in fact leaving the regulation open to interpretation can be a feature from the point of view of authority.

The only interpretation that matters is that of the Authority of enforcement and judgement. The implementer’s interpretation doesn’t hold much weight.

We can say what we earnestly believe the regulations mean, and how they can be met, but if the authorities say “not good enough” that’s all that matters.