Clause 9(3) states that the guidance may include provision on the role, functions and appropriate training and qualifications of an ISVA and IDVA. We find no reason why it should not be required to do so. If a role is to be recognised in statute it is not unreasonable to suggest the criteria defining that role be also set out, not least if people performing that function are to have consequent rights such as being allowed to support complainants in court. The Ministry of Justice will also need to clarify how any guidance produced with respect to ISVAs corresponds to existing guidance published by the Home Office.