(30 Dec 2019, 6:34 pm)tyresmoke wrote I think it was a case of literally assuming only registered services would be encompassed by the regulations, and as nobody had said otherwise until a few months ago then everyone thought that was the case. I read it differently in that all fare paying services would be included, but there we go. I didn't expect fares paid off-bus would be included, eg private schools & rail replacement.
In the last hour there's been an announcement that PSVAR has been delayed until 31st July, to cover the rest of 2019/20 school year, for home to school services only. Rail replacement will still have to comply from 1st February, and registered services (presumably!) from 1st January.

This isn't meant to be dig at you personally, but I don't see how you can think all fare paying services would be included, but not fares paid off-bus.
At the end of the day, money is changing hands for that service to be run, it doesn't matter when or where that money was paid, or who paid it. 

This is the issue with the way our government/legal system works. They prefer to leave things up to interpretation rather than setting things in stone, which in some cases is very helpful as not every situation is the same, but in this case has caused a plethora of issues