Enforcement
The Justice Department of the Velocity Interoperability Network is responsible for the enforcement of the rules and standards of the Velocity Interoperability Network. Enforcement is carried out by the Department's Enforcement Office, which monitors compliance, corresponds with members about apparent failures, issues compliance notices and, where a notice is not complied with, brings an application before the Enforcement Division of the Network Court.
Enforcement is not a substitute for dispute resolution. Where two members disagree about what a rule requires of one another, the matter belongs to the Dispute Resolution Service and, if mediation does not settle it, to the General or Standards Division. Enforcement concerns the obligations a member owes to the Network as a whole, and an enforcement application may be brought only by a Network department.
Most enforcement ends at the notice stage. Of the 22 enforcement matters transferred to the Department during the transition period from 10 August to 5 September 2026, 14 were concluded before establishment, in every case by compliance with a notice or by an undertaking recorded by an interim panel. Eight remain open and have been allocated to the Enforcement Division.
Grounds for enforcement
- Failure to meet an interoperability standard
- A service that a member offers to the Network does not conform to a published standard, and the member has not brought it into conformance within the period allowed by the standard.
- Failure to share data as required
- A member has not supplied a return, a record or an index entry that the rules of the Network require it to supply, or has supplied it so late or so incompletely that other members cannot rely on it.
- Misuse of shared Network resources
- A member has used identifiers, capacity or credentials allocated to it for a purpose other than the one for which they were allocated, or has charged others for access to a resource maintained at Network expense.
- Operating without a certification or licence
- A member is operating a service for which a certification or licence is required and has none, or continues to operate after one has been withdrawn or suspended.
- Failure to comply with an order of the Court
- A member has not done what an order of the Network Court required it to do within the period the order allowed.
How an enforcement matter proceeds
Step 1: The Enforcement Office identifies a possible failure
From a report by another member, from a return supplied to a Network department, or from its own monitoring of published conformance results.
Step 2: The Office writes to the member
It sets out what it believes has happened, the rule or standard concerned and the material it relies on, and invites the member to respond within 14 days.
Step 3: A compliance notice is issued
Where the response does not resolve the matter, the Office issues a compliance notice specifying what must be done and the period allowed, which is not less than 21 days unless other members are being harmed.
Step 4: The member complies or proposes a remedial plan
A member may comply within the period, or propose a plan setting out the steps and dates by which it will comply. The Office may accept a plan and record it against the notice.
Step 5: An application is lodged with the Enforcement Division
If the notice is not complied with and no plan is accepted, the Office lodges an application with the Registry, attaching the notice and the correspondence, and the member is served in the ordinary way.
Step 6: The Division hears the application
The member may answer the application in writing within 21 days and may appear at the hearing. The Division may make an order, record an undertaking or dismiss the application.
Step 7: Compliance is monitored and reported
The Office reports to the Court at the end of the period allowed by the order, and the report is recorded in the register entry for the matter.
Orders the Court may make
- Compliance order
- An order requiring a member to do a specified thing, or to stop doing it, within a specified period. The Enforcement Office reports to the Court on compliance at the end of the period.
- Suspension of access
- An order suspending a member's access to one or more Network services until it complies. Suspension is sought only where continued access would harm other members, and is heard by three judges.
- Direction to publish
- An order requiring a member to publish a notice to the other members describing what went wrong, what has been done about it and by when the position will be corrected.
- Undertaking recorded by the Court
- Where a member offers to take specified steps, the Court may record the undertaking instead of making an order. An undertaking is enforced in the same way as an order.
- Order as to costs
- Each party ordinarily bears its own costs. The Court may order otherwise where a member has resisted an application that had no reasonable answer, or has failed to comply with a direction.
Suspension of access
The suspension of a member's access to Network services is the most serious order the Court may make. It is sought only where the continued operation of a non-conforming service would harm other members, and it is heard by three judges rather than one.
A member subject to a suspension order may apply at any time for it to be lifted on evidence that the failure has been corrected. The application is listed within five working days and is ordinarily decided on the papers.
Compliance notices in the transition period
Twenty-two compliance notices were issued by the interim panels convened by member organisations before the Department existed, and were transferred to the Enforcement Office on establishment. Fourteen had been complied with or answered by an undertaking; eight remain open. The six notices below are a selection, given to show the subjects the notices covered and the form in which their status is recorded. Members are identified in the register of decisions where a matter reaches the Court; a notice that is complied with is not attributed to a named member.
| Notice | Date issued | Subject | Status at 6 September 2026 |
|---|---|---|---|
| CN/2026/0003 | 13 August 2026 | Conformance of a message-signing service | Complied within the period allowed |
| CN/2026/0007 | 18 August 2026 | Monthly data-sharing return not supplied | Remedial plan accepted; returns resumed |
| CN/2026/0011 | 24 August 2026 | Charging for access to a shared index | Undertaking recorded by the interim panel |
| CN/2026/0016 | 27 August 2026 | Operating a service after a certification was withdrawn | Open; transferred to the Enforcement Division |
| CN/2026/0019 | 1 September 2026 | Use of allocated identifiers for another purpose | Open; remedial plan under consideration |
| CN/2026/0022 | 4 September 2026 | Incomplete index entries supplied to other members | Open; response awaited |
Periods in enforcement
| Step | Period | Reckoned from |
|---|---|---|
| Response to the Office's first letter | 14 days | From the day the letter is served |
| Period allowed by a compliance notice | Not less than 21 days | From the day the notice is issued |
| Proposal of a remedial plan | Before the notice period expires | A plan proposed afterwards may still be accepted |
| Answer to an application | 21 days | From the day service of the application takes effect |
| Report on compliance with an order | 10 working days | From the end of the period allowed by the order |
Reporting a failure and enquiries
A member or a department that believes another member is not complying with a rule or standard of the Network may write to the Enforcement Office at contact@justice.gov.vin. Set out the rule or standard concerned, what is said to have happened and the dates, and attach any material relied on. The Office acknowledges a report within five working days and tells the reporting member what it has decided to do.
The Office does not act on a report that is really a dispute between two members; see Disputes for the stages that apply to those. The procedure before the Enforcement Division is governed by the Rules of Procedure, and every order made is published in the register of decisions.