9 September 2026. Bounded acquisition closed. This packet establishes a dated public procedure and a later procurement specification, with attributed delivery accounts. It does not certify the currently deployed portal or a September 2026 operating policy. No operational list, account, form, target website or gated tender was accessed.
The decisive link is an assessment by police between a rightsholder's evidence and a list distributed for advertising decisions. The strongest acquired safeguard is an express opportunity to challenge police action and immediate removal when evidence shows that the site no longer commits offences. The unresolved step is what happens to decisions already made by recipients when an entry changes. Funding for capacity does not by itself give a contributor the power to approve a listing.
The disclosed rule and its limits
[College of Policing FOIA-2021-094](http[local research file] response dated 17 September 2021, contains an embedded Policing Fraud document labelled “Revised 070119 MJB”. Preserve that literal revision identifier; a separate adoption date and continuing application in 2026 were not established. Original retained as list-college-foi2021.pdf; PDF 37–39 / printed 25–27 is the complete Operation Creative case study. PDF 38 was visually checked.
The procedure requires PIPCU to assess investigation quality, lawful evidence and a rightsholder/nominee statement meeting a standard sufficient to support prosecution. Qualifying referrals can be distributed to advertising businesses. The Head of Unit determines tactics case by case. Website operators may challenge police activity; evidence of cessation of offences triggers immediate removal. Police first contact operators, offer a route to legitimate operation through rights associations, and review again if positive contact fails. Payment-service withdrawal is described as a request to the provider or merchant bank. It is not a payment-provider command conferred by this document.
The preceding text cautions against unlawful use of compulsory powers solely for disruption. The case study does not specify prior court adjudication as an inclusion condition. That is a description of this procedure, not a comprehensive opinion about legal powers. It provides no fixed recurring review interval, response deadline, independent merits reviewer or recipient-wide correction instruction. Its cessation wording also does not spell out a separate mistaken-original-inclusion test. The general challenge opportunity should not be erased because those details are absent.
The FOI letter's own 40-working-day review route concerns access to information, not IWL inclusion. Likewise, Ashiko's separately acquired DCI approval rule is not imported here. The stated Creative decision actor is the Head of Unit.
Later public portal specification locates admission rights
[Find a Tender notice 012517-2024](http[local research file] published 17 April 2024 at 14:38, is a City of London Corporation contract notice, not an executed operating manual. PDF 4, section II.2.4, describes the proposed allocation:
| Actor | Specified role |
|---|---|
| Copyright holders and representatives | Submit domains with supporting evidence |
| Police officers as administrators | Review and accept or reject submissions |
| Investigators | Submit cases and see limited data |
| Users | View some data without editing it and download IWL domains |
Two administrator levels are described as desirable. This supports a police-controlled approval design; it does not prove permissions were implemented, that every applicant is admitted, or that the software supplier decides infringement. The notice provides no new challenge procedure or correction-propagation rule. Its High Court procurement-review section concerns the tender, not website operators' list appeals. The full technical pack expressly requires an NDA; it was not requested.
The complete official-reader notice is retained in list-tender-and-award.reader.txt; original GET returned 403. The related award PDF, [027681-2024](http[local research file] failed through both the reader and ordinary GET. Its search-only supplier/value details are not adopted. A separate 2025 procurement search result is likewise only a lead, not proof of the same contract or deployed system. No failed route was retried. The tender's inconsistent annual-versus-total value wording was inspected but no budget amount is needed for this authority conclusion.
Attributed referrals and effects
The retained [IP Crime and Enforcement Report 2018/19](http[local research file] PDF 59 / printed 55, supplies an operational account: a referral is followed by a cease-and-desist notice and attempted contact before listing. It dates the IWL's creation to 2014 and reports 1,643 websites recorded by April 2019, alongside a separate 1,995 suspended since creation. Those are different measures.
The PRS for Music contribution, PDF 113 / printed 109, reports its Rights Protection Unit submitting 138 website referrals. This appears in the2018/19 report, but the Operation Creative paragraph does not specify the counting period; nearby2018 dates concern separate work. This establishes PRS's attributed exercised supply of referrals. It does not show that all 138 were accepted or identify the advertisements removed because of each referral. Its surrounding MAPS/search/app achievements are different channels and must not be counted as IWL results.
The retained [2022–2027 counter-infringement strategy](http[local research file] “Internet/e-commerce”, explicitly calls industry intelligence the main referral source and describes sharing the IWL to disrupt advertising revenue. Its 5,008 takedowns since 2014 is attributed to the wider collaborative operation, which includes multiple tactics. It is not a measured causal effect of list inclusion alone.
[City of London Police, 6 February 2023](http[local research file] reports White Bullet research finding a 58% decrease in UK advertising on IWL websites between January and December 2022, and an estimated GBP 6 million decrease in advertising revenue from UK traffic over that period. The office presents this as operational success; White Bullet's CEO also speaks as a collaborator. The underlying study, sampling, list-composition changes and counterfactual were not acquired. Preserve this as a police-published, supplier-attributed estimate, not observed cash withheld, seized money or proof that the IWL alone caused the change. The article separately reports 750 subscribers and 682 domains suspended in 2022; subscriber access, listing and suspension remain distinct outcomes.
What the sequence establishes
Candidate directional relations for later review are: rightsholder/nominee to PIPCU, evidential referral; PIPCU to referred domain, quality assessment; police administrator to portal submission, proposed accept/reject right; Head of Unit to operational tactics, dated decision authority; PIPCU to advertising recipients, distribution for action; website operator to PIPCU, challenge opportunity; PIPCU to list entry, conditional immediate removal; PRS to PIPCU, reported 138 referrals; White Bullet to police announcement, attributed measurement input. None is a new case addition.
The strongest rival to a simple “industry dictates the list” interpretation is substantive police screening followed by recipients' separate choices. The published rules support that formal distinction; their practical quality cannot be inferred from the rules alone. Conversely, the presence of screening and a challenge promise does not establish that reviews are fast, independent or consistently reflected downstream.
A finite next discriminator is a current public IWL operating procedure or redacted inclusion/challenge decision with timestamps, reasons, reviewer, removal notice and recipient notification. The likely holder is PIPCU/City of London Police; relevant product evidence would be an accepted technical specification or change-event protocol. No claim is made that a particular unpublished document exists. This would distinguish effective correction from list-only deletion and establish whether the dated safeguards remain operative.
Custody and exact scope
list-captures.json contains original/derivative hashes, URLs, dates, acquisition outcomes and scoped reads. The College original is SHA256 245cd690a2643290ec29690933b65833b3283fb11687282f9d4083f0357ddf76. Reused 2019 report and 2022 strategy originals remain at their prior paths with hashes e0b6e4b753ece534e35a20b46cf2aeeb4b147588e99576f746f083c621bade97 and 9dcb6d69ad37942b0b4005543be05e9f4561eb854659d149e0f95510067e0654. This run freshly read the previously excluded Creative passages; it does not relabel old captures as new acquisitions.
College scope: PDF 1–3 cover/access review, PDF 13 contents/version, PDF 37–39 case study and adjacent caution; PDF 12 incidental; visual PDF 38. Report scope: complete PDF 59 and 113, incidental PDF 75; the unrelated activities on those pages were not adopted as IWL evidence. Strategy scope: original HTML Internet/e-commerce section through the Creative paragraph. Tender scope: full public 10-page reader, especially II.2.4; no technical pack. Police announcement scope: complete substantive official-reader lines 50–67 including date and closing figures; no underlying White Bullet study. Neither the 159-page College bundle nor either long report was read in full.
Searches were confined to the exact operation/list, challenge/review and official portal notice. No newer public review cadence or exercised correction case was located in this finite pass. That is a scoped gap, not proof no procedure or correction exists. Acquisition closed before any supplier-contract, operational-list or wider advertising branch.