The Testing the Waters Consortium - a coalition of water monitoring experts bringing together technology firms, NGOs, citizen scientists, regulators, and water companies - has published its response to the Government's Water White Paper.

While welcoming commitments to end Operator Self Monitoring and embrace digitisation, the Consortium raises serious concerns about the lack of detail on how improved water monitoring will be achieved - particularly the omission of citizen science, funding for statutory monitoring, and emerging pollutants.

Water monitoring is critical to restoring our waterways. Without adequate detail in the upcoming Water Reform Bill, the Government risks making investment and policy decisions based on a poor understanding of the environment.

Read our full response below.

Testing the Waters Consortium: Water Monitoring is Critical to Restore our Waterways - Yet the Water White Paper Falls Short on the Detail

The Testing the Waters Consortium (TWC) is a coalition of water monitoring experts, bringing together technology firms, NGOs, citizen scientists, regulators, and water companies. In November, we published a paper in response to Recommendation 13 of the Independent Water Commission:

“Future water monitoring programs should be reviewed and adequately resourced, to accurately reflect the state of the environment.”

The Water White Paper dedicated just a few paragraphs to monitoring, leaving the TWC deeply sceptical that the upcoming Water Reform Bill will lead to the transformation in water monitoring needed to understand, protect, and restore the environment. The few elements which the Consortium welcomes - including ending Operator Self Monitoring - were previously announced.

We remain concerned over the total lack of mention for citizen science, funding for statutory monitoring, and emerging pollutants, from PFAS to microplastics.

The Government marks its intent to “reward companies for delivering outcomes that matter most to customers including public health, the environment, and long-term resilience.” It will also continue to fine companies where performance does not meet legal standards. For this ‘carrot and stick’ approach to be effective, the monitoring system must adequately reflect the environment in order to accurately target and assess company performance.

The White Paper provides the welcome understanding that monitoring is essential not only in the water industry itself, but in guiding local planning and decision making, and representing the true state of our waterways to the public.

Given the Government’s apparent understanding of the key role that monitoring must play if these are to be “once in a generation” reforms - there is a glaring lack of detail in how improved monitoring will be achieved.

Areas of omission:

• Funding for statutory monitoring: The IWC recognised that the EA and NRW have been unable to adequately monitor the environment due to resource constraints. With no commitment to new funding, the new regulatory system may be no better able to monitor the environment than its predecessor.

• Citizen science: The White Paper omits citizen science altogether, despite the fact that it plays a vital role in restoring areas affected by pollution and in identifying its sources - providing the evidence needed to drive change in catchments.

• National catchment data platform: Whilst the Government does mention a drive towards digitisation and automation, there is no explicit commitment to the creation of an open catchment monitoring platform. The TWC believes a single, open, cross-sectoral data platform is needed to close the gap between data collection and decision making at the local, regional and national scale.

• Emerging pollutants: The threats posed by emerging pollutants, such as PFAS, microplastics, and anti-biotic resistant bacteria are widely understood as posing significant risks to public health and the environment. Their omission in the White Paper is concerning, and the Consortium urges the Government to update the list of monitored pollutants to better reflect the risks posed to humans and wildlife.

Areas of support:

• Ending Operator Self Monitoring (OSM) for open monitoring: The TWC strongly supports the commitment to end OSM, though notes that this is nothing new, following its announcement on 21st July 2025. There is little detail as to what the new Open Monitoring system will entail, but we welcome the commitment to make data accessible to the public in near-real time to restore public trust in the system.

• Digitisation and automation: For too long, data collected by the water industry, regulators, and citizen scientists has been siloed and hosted in antiquated data systems. The commitment to digitise and automate the monitoring process is long overdue and welcomed by the TWC.

• Technological advancements: Monitoring equipment manufacturers have made great leaps in recent years in the accuracy and cost-effectiveness of monitoring. Further investment and rapid adoption is needed to deliver improvements in monitoring. There is also great potential to integrate remote sensing and AI for large datasets and the TWC demands more detail on the role of these technologies in future monitoring systems.

• Bathing waters: The November 2025 reforms to the Bathing Water Regulations, and scheduled changes in May 2026, in abandoning a one-size-fits-all statutory monitoring summer window for designated bathing sites could improve monitoring in these key areas for public health. It is crucial that local groups and citizen scientists are included in the development of monitoring plans in order to effectively implement changes.

• Small waters: The White Paper indicates that monitoring should reflect the whole water environment, which could imply a shift to monitor more smaller waters, beyond the current focus on main rivers - a move which the TWC supports, provided monitoring of small waters is additional, not at the expense of monitoring of main rivers.

Minister Hardy has indicated that many of the reforms to monitoring can be achieved without the need for primary legislation through the upcoming Water Reform Bill. Given the absence of any concrete announcement of reforms either in the Water White Paper or elsewhere, this provides little comfort. A well-funded, collaborative water monitoring system will be essential for the Government to deliver on its promises to clean up our rivers, lakes and seas. Without radical change, investment and policy decisions risk being made on the basis of a poor understanding of the environment. The TWC demands further detail on reforms to water monitoring, which the Government itself acknowledges is essential to restoring public trust, but has failed to address meaningfully in the Water White Paper.

This release is submitted on behalf of the Testing the Waters Consortium, with the backing of Angling Trust, Aquasensor, Avonvale River Action Group, Campaign Against River Pollution (CARP), ClearWater Sensors, Earthwatch, HoTWater, Proteus, Thames 21, and Windsor RiverWatch.