theres something in European legislation that we have signed up to that's basically a right to work,with this registration/guidance not being law your right to work should overrule the failings in this card scheme,needs a few test cases going to court to set a precedent but if your losing money because a scheme is failing you then I think its impeding your human right to work,suppose it depends on proving competence aswell but im sure your cv and references will more than back your case,will look up the exact law but its defo something to look at for the blokes who are being stopped and prevented from working because of a guidance scheme when they were previously able to do so,let alone the failings in that scheme!