As the EHRC pointed out in response to the consultation on our draft Bill: “The operation of these exceptions does not depend on the existence of a GRC, and they would continue to operate as they do now – and have done since 2010 – should the draft Bill become law. We note that the EA 2010 became law several years after the GRA, and had the intention been for a GRC to be a pivotal factor in the operation of the exceptions, the EA 2010 could have been drafted as such – but it was not.