Sheep and Goats (Records, Identification and Movement) (England) Order 2009
What this means for your business
- Enforced by
- Environment Agency, OEP, OPRED, NRW, SEPA
- Applies to
- United Kingdom
- On this page
- 57 compliance obligations, 3 practical guides
What you must do
57 compliance obligations under this legislation.
Management duties 7
Apply for an aircraft emissions monitoring plan and keep it up‑to‑date
If you run aircraft that must monitor emissions, you must submit an application under the 2018 regulations. When the regulator issues the plan, it must contain all required conditions and replace any earlier plan. You also have to agree to any amendments the regulator requests so the plan remains compliant.
Apply for and comply with changes to your emissions monitoring plan
If your business operates aircraft and has an emissions monitoring plan, you must ask the regulator to change the plan whenever the plan itself requires you to do so. You also have to follow any changes the regulator tells you to make, especially if you fail to apply for a variation yourself.
Apply for an emissions monitoring plan within 42 days of starting aircraft operations
If your business starts operating aircraft, you must submit an application to the regulator for an emissions monitoring plan. This must be done within 42 days of the date you become an aircraft operator, unless you already have an approved plan and the regulator agrees otherwise.
Ensure allowances are allocated to your installation on time
If you run an installation that is part of the UK greenhouse gas emissions trading scheme, you need to have the appropriate allowances transferred to your operator account. The regulator must do this in line with the published allocation table – usually by 28 February each scheme year (or ASAP after the table is released for 2021). If the table is later updated and you are entitled to more allowances, the extra ones must also be transferred promptly.
Maintain an aircraft operator holding account to receive allowances
You must have an active aircraft‑operator holding account before any aviation emission allowances can be allocated to you. If the regulator withholds allowances because you were not recognised as an operator, you must promptly inform the regulator when you become an operator so the hold is removed and the allowances are allocated.
Monitor aviation emissions and follow your emissions monitoring plan
If you run an aircraft operation, you must continuously track the greenhouse‑gas emissions from your flights as set out in the Monitoring and Reporting Regulation 2018 and the written procedures in your own emissions monitoring plan. You also have to obey any specific conditions that appear in that plan under the referenced articles.
Obtain approval of monitoring methodology plan to receive allowances
Your business can only receive emissions allowances for your installation if the regulator has approved your monitoring methodology plan. Until that plan is approved, any allowances that would normally be allocated are held back, so you’ll receive no allowances.
Other requirements 2
Comply with enforcement notices issued by the regulator
If the regulator (or the registry administrator) believes you have broken, are breaking, or may break a requirement under the Sheep and Goats Order, they can serve you with an enforcement notice. You must carry out the actions set out in that notice, within the time‑frame they give, or you risk enforcement action.
Return aviation emissions allowances if you’re no longer entitled
If your business was allocated aviation carbon allowances and the allocation table is later changed, or you are not an aircraft operator for that year, or the allowances exceed your actual emissions (for 2024‑2025), you must give those allowances back. The regulator can issue a notice telling you to surrender the excess allowances.
Payments and fees 3
Return unauthorised emissions allowances
If you receive a notice saying you hold emissions allowances you are not entitled to, you must give those allowances back. The notice will tell you how many, why they’re not yours, how to return them and the deadline. You must follow the instructions, and if you are transferring allowances to a new operator you must also ensure the new operator complies.
Surrender emissions allowances each scheme year
If your business runs an installation and holds a greenhouse‑gas emissions permit, you must hand over the required carbon allowances every year (or any part of a year) as set out in the permit. This is a recurring compliance task that must be completed for each scheme year while the permit is active.
Surrender emissions allowances to the scheme
If your business operates aircraft and is part of the emissions trading scheme, you must give back an amount of allowances that matches the tonnes of CO₂ your flights emitted in that scheme year. You have to do this by 30 April of the following year.
Offences and prohibitions 34
Carry out regulated activity without a permit
Unlimited fineIf you operate a plant that is covered by the Greenhouse Gas Emissions Trading Scheme and you carry out a regulated activity without the required permit, you will be liable for a civil penalty. The penalty is calculated based on the cost savings you achieved and the amount of emissions released, multiplied by the carbon price for the year, and can be increased to ensure it exceeds any benefit you gained.
Carry out regulated activity without a permit
Unlimited fineIf you run a sheep or goat installation and carry out a regulated activity without first obtaining the required permit, you will be liable to a civil penalty after the scheme year ends. The penalty is calculated as the cost you saved by not having a permit plus your reportable emissions multiplied by the carbon price, and the regulator may increase it to ensure you don’t gain any economic benefit.
Fail to apply for or revise emissions monitoring plan
Fine up to £45,000If your airline or charter company does not submit an emissions monitoring plan to the regulator when required, or does not submit a revised plan on time, you commit an offence. On conviction you will face a civil penalty of £20,000 plus a daily charge of £500 for each day the plan is overdue, up to a total of £45,000. There is no prison term for this breach.
Fail to apply to surrender permit
Fine up to £5,000If you run a sheep or goat installation and you do not submit an application – or submit it late – to surrender your operating permit, you are committing an offence. On conviction you will be liable to pay a civil penalty of up to £5,000.
Fail to apply to surrender permit
Fine up to £5,000If the operator of a greenhouse‑gas emissions installation does not submit an application to surrender its permit, or submits it late, the business commits an offence. On conviction the operator faces a civil penalty of £5,000. The Environment Agency can enforce this penalty.
Fail to comply with condition of emissions monitoring plan
Fine up to £45,000If your airline (or any aircraft operator) does not meet a condition set out in an emissions monitoring plan – or is late in doing so – you commit an offence. On conviction you will be ordered to pay a fixed penalty of £20,000 plus a daily fine of £500 for each day the breach continues, up to a total of £45,000. No imprisonment is attached to this civil penalty.
Fail to comply with deficit notice
Unlimited fineIf your business receives a deficit notice requiring you to surrender carbon allowances for sheep and goats and you either do not surrender the required allowances or submit them late, you breach the notice. On conviction you will face a civil penalty of 1.5 times the carbon price for each missed allowance, plus a daily charge of £1,000 for every day the shortfall remains unresolved.
Fail to comply with emissions monitoring plan condition
Fine up to £45,000If your business operates aircraft and has an emissions monitoring plan, you must meet every condition of that plan on time. Failing to do so – or being late – makes you liable for a civil penalty of £20,000, plus a daily charge of £500 for each day the breach continues, up to a total of £45,000. The Environment Agency can enforce this penalty.
Fail to comply with enforcement notice
Fine up to £45,000If your business receives an enforcement notice under the Greenhouse Gas Emissions Trading Scheme and you do not follow its requirements (or you miss the deadline), you will be hit with a civil penalty. The default fine is £20,000, and you’ll also incur a daily charge of £1,000 for each day you remain out of compliance, up to a total of £45,000.
Fail to comply with enforcement notice (sheep & goats)
Fine up to £45,000If you receive an enforcement notice under the Sheep and Goats Records, Identification and Movement Order – for example, a notice requiring you to keep proper records or control animal movement – and you do not comply with it, or you are late in complying, you commit an offence. On conviction you will be liable for a civil penalty of up to £45,000 (a £20,000 fixed fine plus a daily charge of £1,000, capped at the total amount).
Fail to comply with greenhouse gas permit conditions
Fine up to £45,000If you operate an installation covered by the Greenhouse Gas Emissions Trading Scheme and you do not meet the conditions of your greenhouse gas permit, hospital or small‑emitter permit, or the requirements set out in surrender or revocation notices, you commit an offence. On conviction you will be liable for a civil penalty of £20,000 plus a daily fine of £500 for each day of non‑compliance, capped at a total of £45,000.
Fail to comply with information notice
Fine up to £45,000If you are served with an information notice under article 75 of the Greenhouse Gas Emissions Trading Scheme, you must provide the requested information by the deadline set in the notice. Failing to do so (or failing to do it on time) creates a civil offence. On conviction you could be ordered to pay a fine of £5,000 plus a daily default fine of £500 for each day of non‑compliance, up to a total of £45,000.
Fail to comply with information notice
Fine up to £45,000If you are served an information notice under article 75 and you do not provide the required information – or you provide it late – you commit an offence. On conviction you will be hit with a civil penalty of £5,000 plus a daily charge of £500 for each day you remain non‑compliant, up to a total of £45,000.
Fail to comply with installation permit conditions
Fine up to £45,000If you run a sheep or goat installation and do not meet the conditions of your greenhouse‑gas, hospital or small‑emitter permit (or fail to act on a surrender or revocation notice), you will be hit with a civil penalty. The regulator can charge a fixed £20,000 fine plus £500 for each day you remain out of compliance, up to a total of £45,000. No imprisonment is involved, but the fine can be substantial.
Fail to comply with notice to return allowances
Unlimited fineIf you receive a ‘notice to return allowances’ under the Sheep and Goats (Records, Identification and Movement) Regulations and you do not follow its requirements – or you do not do so on time – you commit an offence. On conviction you will be liable to pay a civil penalty of £20,000 plus a daily charge of £1,000 for every day the breach continues.
Fail to comply with notice to return allowances
Fine up to £20,000If you receive a notice requiring you to return emission allowances and you do not comply – or you do so late – you commit an offence. On conviction you face a civil penalty of £20,000 plus a daily charge of £1,000 for each day the breach continues, starting from the day the notice is issued.
Fail to comply with regulator’s information or record request
Unlimited fineIf you refuse or neglect to meet a requirement the regulator imposes – for example providing records, answering questions, attending a meeting or allowing inspection – you commit a criminal offence. The offence also covers actively obstructing the regulator or preventing others from cooperating. On conviction you face an unlimited fine, which can be imposed either in the Magistrates’ Court or the Crown Court.
Fail to comply with regulator’s inspection or information requirement
Unlimited fineIf a person (including a business) does not obey a requirement from the regulator – for example refusing to let inspectors on the premises, not providing records, or stopping someone from answering questions – they commit a criminal offence. Conviction can lead to a fine (unlimited amount) and the case may be tried in either the magistrates’ court or Crown Court. There is no custodial sentence attached to this offence.
Fail to monitor aviation emissions
Fine up to £45,000If your company operates aircraft and does not monitor the emissions of those flights as required by article 32(1), you commit an offence. The Environment Agency can impose a civil penalty of £20,000 plus a daily fine of £500 until you start monitoring, but the total fine cannot exceed £45,000. No imprisonment is involved.
Fail to monitor aviation emissions
Fine up to £45,000If you operate aircraft and do not monitor aviation emissions in line with article 32(1), you commit an offence. On conviction you face a civil penalty of £20,000 plus a daily fine of £500 for each day the breach continues, starting from the day you receive the first notice, up to a total maximum of £45,000.
Fail to pay civil penalty for emissions breach
Unlimited fineIf you run a hospital or other small emitter and are issued a civil penalty for exceeding your emissions target, you must pay that penalty by the due date shown on the notice. Failure to do so triggers an additional penalty – a further charge of 10% of the original penalty plus a daily charge of £150 for each day the payment is late, up to a total of £13,500.
Fail to pay civil penalty for exceeding emissions target
Unlimited fineIf your hospital or small emissions installation exceeds its emissions target and you receive a civil penalty, you must pay that penalty by the date shown on the notice. If you do not pay on time, you will face an extra penalty of 10% of the original amount plus a daily charge of £150, up to a maximum of £13,500.
Fail to submit aviation emissions report
Fine up to £45,000If you operate an aircraft you must send a verified report of your aviation emissions to the regulator on time. Failing to do so (or sending it late) is a civil offence. On conviction you will be ordered to pay a £20,000 fine plus a daily charge of £500 until the report is received, but the total charge cannot exceed £45,000.
Fail to submit aviation emissions report on time
Fine up to £45,000If your company operates aircraft and does not send a verified report of aviation emissions to the regulator – or sends it late – you breach this offence. On conviction you will face a civil penalty of up to £45,000, made up of a £20,000 fixed fine plus daily charges of £500 for each day the report is overdue.
Fail to submit emissions monitoring plan application
Fine up to £45,000If your aviation business does not lodge an application for an emissions monitoring plan (or fails to submit a revised plan when required) by the deadline, you commit an offence. On conviction you will be hit with a £20,000 fine plus a daily charge of £500 for each day the application is late, up to a total of £45,000.
Fail to submit information required by article 27A
Fine up to £45,000If the operator of a greenhouse‑gas installation does not provide the information required by article 27A, or provides it late, the business commits an offence. The Environment Agency can impose a civil penalty of £5,000 plus a daily fine of £500 for each day the breach continues, with the total fine capped at £45,000. The penalty is a civil fine only – there is no imprisonment.
Fail to submit required information under article 27A
Fine up to £45,000If you operate a sheep or goat installation and do not provide the information required by article 27A (or you provide it late), you commit an offence. On conviction you will face a civil penalty of up to £45,000 – a fixed £5,000 charge plus a daily charge of £500 for each day the breach continues.
Fail to surrender allowances after deficit notice
Unlimited fineIf you receive a deficit notice under the greenhouse‑gas emissions trading scheme and do not surrender the required allowances (or miss the deadline), you will be subject to a civil penalty. The penalty is calculated as 1.5 times the carbon price for each allowance you fail to surrender, plus a daily charge of £1,000 for every day the breach continues.
Fail to transfer or surrender allowances after under‑reporting discovered
Unlimited fineIf you discover that you have under‑reported emissions after you have already transferred allowances, you must promptly transfer or surrender the correct number of allowances. Failing to do so incurs a civil penalty of 1.5 times the carbon price for each missed allowance, plus a daily fine of £1,000 for every day the breach continues.
Fail to transfer or surrender emissions allowances after under‑reporting discovered
Unlimited fineIf your business discovers that it has under‑reported its emissions after it has already transferred allowances, you must still transfer or surrender the correct number of allowances. Failing to do so triggers a civil penalty calculated at 1.5 times the carbon price for each missed allowance, plus a daily default fine of £1,000 for each day the breach continues.
Provide false or misleading information
Fine up to £50,000If you give false or misleading information in any application, notice, permit condition or emissions report required under the Sheep and Goats (Records, Identification and Movement) Order, you commit an offence. On conviction you can be hit with a civil penalty of up to £50,000. No prison term applies.
Provide false or misleading information in emissions applications
Fine up to £50,000If your business submits an application, notice, permit condition, monitoring plan or aviation emissions report under the Greenhouse Gas Emissions Trading Scheme Order and the information is false or misleading, you commit an offence. The penalty is a civil fine of up to £50,000. The offence applies to any person who provides the information.
Refuse regulator access to premises
Fine up to £50,000If you are the person who controls a sheep or goat premises and you stop the regulator or an authorised inspector from entering when they have the right to do so under the law, you commit an offence. On conviction you face a civil penalty of up to £50,000. No imprisonment is attached to this breach.
Refuse regulator access to premises
Fine up to £50,000If you are the person in control of a premises covered by the Greenhouse Gas Emissions Trading Scheme and you prevent the regulator or an authorised person from entering when they request access under article 39(3), you commit an offence. The regulator can impose a civil penalty of up to £50,000. You must ensure staff allow such access to avoid the fine.
Record keeping 2
Enter approved ETS allowances in the allocation table
Each year, when the UK ETS authority approves the number of free emission allowances your installation can receive, you must record that figure in the correct column of the allocation table (A, B or C) and adjust the totals if any increases or decreases are approved. The table must always show the summed total in column C for the scheme year.
Keep records of aviation emissions for free allowance eligibility
If you operate aircraft under the 2021‑2025 allocation period you may receive some free emissions allowances, but only if your yearly emissions do not exceed the allowances you claim. In practice you need to record your emissions for each scheme year and make sure you do not claim more free allowances than you actually emit.
Registration and licensing 1
Update regulator when you move your registered office
If your aircraft operator moves its registered office or place of residence into a different UK regulator area, you will automatically be regulated by the new area from 1 January 2026. The same applies to a foreign operator that takes up a UK office that ends up in a different regulator area. In practice this means you need to keep your contact details up‑to‑date with the UK regulator and be prepared to comply with new rules when the change takes effect.
Reporting and filing 8
Apply to transfer aviation free allocation after business reorganisation
If your aviation business is reorganised in a way that changes the activity that earned you free emissions allowances, you must ask the regulator to move the appropriate part of those allowances to the new entity. You need to provide evidence of the reorganisation, state how many allowances should be transferred and confirm that everyone involved is aware of the application.
Provide accurate free‑allocation applications and activity reports
If you own or run a sheep or goat installation, you must fill out the free‑allocation form and submit correct activity reports. If the regulator finds a mistake, they will recalculate your allowance and let you know the new figure – you must keep your records up to date and accept the corrected allowance.
Resubmit emissions monitoring plan within 31 days of refusal
If the regulator rejects your application for an emissions monitoring plan, they must give you a notice explaining why and what changes are needed. You then have to send a corrected (revised) application within 31 days of that notice. Failing to do so may delay or prevent your plan being issued.
Return excess emissions allowances for your installation
If your business receives emissions allowances for a sheep or goat installation and the allocation table is later updated to reduce those allowances, you must give back any allowances you are no longer entitled to. The regulator will send you a notice telling you how and when to do this.
Submit and correct your emissions reports
If you run an installation that emits pollutants or operate aircraft, you must send the regulator a report of those emissions as required by your permit or aviation rules. If a verifier points out any errors that you do not fix, the regulator can decide your emissions for you and will tell you what corrections are needed. You must then provide that information and make the corrections.
Submit application for aviation free allocation entitlement
If your business had aviation activity before 1 January 2021, you can apply for free emissions allowances. You must send an application that includes the required historic tonne‑kilometre data, statements about any business reorganisations (or evidence of them), and any special reserve information, by the deadline that applies to you.
Submit installation details to regulator by 30 June 2025
If you run an installation that has (or is applying for) a permit, is an ultra‑small emitter, or has a pending permit, and you are not seeking free allocation for the 2027‑2030 period, you must send the regulator specific information about the plant, its activity and why you’re not applying for free allocation. The information has to be lodged between 1 April 2025 and 30 June 2025.
Submit written appeal and grounds within 47 days
If you want to challenge a decision made by the regulator or the registry administrator under the Sheep and Goats Order, you must send the Planning Appeals Commission a written notice of appeal together with the reasons for the appeal and pay any required fee. This must be done before 47 days have passed since the decision became effective. You can later withdraw the appeal by notifying the Commission.
Penalties for non-compliance
34 penalties under this legislation. 11 carry an unlimited fine.
Carry out regulated activity without a permit
Unlimited fine
Carry out regulated activity without a permit
Unlimited fine
Fail to comply with deficit notice
Unlimited fine
Fail to comply with notice to return allowances
Unlimited fine
Fail to comply with regulator’s information or record request
Unlimited fine
Fail to comply with regulator’s inspection or information requirement
Unlimited fine
Fail to pay civil penalty for emissions breach
Unlimited fine
Fail to pay civil penalty for exceeding emissions target
Unlimited fine
Fail to surrender allowances after deficit notice
Unlimited fine
Fail to transfer or surrender allowances after under‑reporting discovered
Unlimited fine
Fail to transfer or surrender emissions allowances after under‑reporting discovered
Unlimited fine
Provide false or misleading information
Fine up to £50,000
Provide false or misleading information in emissions applications
Fine up to £50,000
Refuse regulator access to premises
Fine up to £50,000
Refuse regulator access to premises
Fine up to £50,000
Fail to apply for or revise emissions monitoring plan
Fine up to £45,000
Fail to comply with condition of emissions monitoring plan
Fine up to £45,000
Fail to comply with emissions monitoring plan condition
Fine up to £45,000
Fail to comply with enforcement notice
Fine up to £45,000
Fail to comply with enforcement notice (sheep & goats)
Fine up to £45,000
Fail to comply with greenhouse gas permit conditions
Fine up to £45,000
Fail to comply with information notice
Fine up to £45,000
Fail to comply with information notice
Fine up to £45,000
Fail to comply with installation permit conditions
Fine up to £45,000
Fail to monitor aviation emissions
Fine up to £45,000
Fail to monitor aviation emissions
Fine up to £45,000
Fail to submit aviation emissions report
Fine up to £45,000
Fail to submit aviation emissions report on time
Fine up to £45,000
Fail to submit emissions monitoring plan application
Fine up to £45,000
Fail to submit information required by article 27A
Fine up to £45,000
Fail to submit required information under article 27A
Fine up to £45,000
Fail to comply with notice to return allowances
Fine up to £20,000
Fail to apply to surrender permit
Fine up to £5,000
Fail to apply to surrender permit
Fine up to £5,000
Practical guidance
Our guides explain how to comply with the requirements above.
Environmental Permit - Part A(1) Installation
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UK Emissions Trading Scheme (UK ETS) compliance
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Sections and provisions
118 classified provisions from this legislation.
Duties 38
- Schedule 10 Appeals to Planning Appeals Commission (Northern Ireland) requests by either party
- s.12 Aircraft operator: change in regulator
- s.13 Aircraft operator: change in registered office
- s.17 Review of UK ETS
- s.19 Cap for trading period
- s.23 Trading in allowances
- s.27 Installations: requirement to surrender allowances
- s.28 Application for emissions monitoring plans An aircraft operator
- s.29 Issue of emissions monitoring plans
- s.30 Refusal of application for emissions monitoring plans
- s.31 Variation of emissions monitoring plans
- s.32 Monitoring emissions and emissions monitoring plan conditions aircraft operator
- s.34 Surrender of allowances by aircraft operators
- s.36 Charging scheme: regulators
- s.44 Enforcement notices
- s.45 Determination of reportable emissions or aviation emissions by regulator
- Allocation of allowances Allocation of allowances other scheme year
- Allocation tables for 2021-2025 and 2027-2030 allo Allocation tables for 2021-2025 and 2027-2030 allocation periods
- Allocation tables: publication, etc. Allocation tables: publication, etc.
- Allocation tables: supplementary Allocation tables: supplementary
- ... and 18 more duties
Offences and penalties 20
- s.40 Powers of entry, etc.
- s.47 Penalty notices
- s.50 Installations: carrying out regulated activity without permit contrary to article 26
- s.51 Installations: failure to comply with conditions of permit, etc.
- s.53 Installations: failure to transfer or surrender allowances where underreporting discovered after transfer
- s.55 Hospitals and small emitters: failure to pay civil penalty for exceeding emissions target
- s.58 Installations: failure to apply to surrender permit
- s.60 Ultra-small emitters: failure to notify where reportable emissions exceed maximum amount
- s.61 Aviation: failure to apply or make revised application for emissions monitoring plan
- s.62 Aviation: failure to comply with condition of emissions monitoring plan
- s.63 Aviation: failure to monitor aviation emissions
- s.64 Aviation: failure to report aviation emissions
- s.65 Failure to comply with enforcement notice ......
- s.66 Failure to comply with information notice
- s.67 Providing false or misleading information, etc.
- s.68 Inspection: refusal to allow access to premises
- s.70 Right of appeal
- Failure to comply with deficit notice Failure to comply with deficit notice
- Failure to comply with notice to return allowances Failure to comply with notice to return allowances
- Installations: failure to submit information under Installations: failure to submit information under article 27A
Definitions 24
- Schedule 2 Meaning of installation and regulated activity combustion unit hazardous waste installation
- s.5 Meaning of operator
- s.6 Meaning of aircraft operator
- Schedule 7 Hospitals and small emitters hospital-qualifying installation maximum amount hospital
- Schedule 9 Appeals to Scottish Land Court appropriate form
- s.14 Meaning of UK ETS authority, etc.
- s.38 Authorised persons authorised person
- s.43 Legal professional privilege
- s.46 Carbon price futures contract relevant period
- s.54 Hospitals and small emitters: exceeding emissions target emissions target
- s.56 Hospitals and small emitters: under-reporting of emissions inflation factor
- s.57 Hospitals and small emitters: failure to notify when ceasing to meet criteria penalty year hospital-qualifying installation maximum amount
- s.59 Ultra-small emitters: reportable emissions exceeding maximum amount maximum amount
- s.69 Interpretation appeal body
- s.71 Appeal body
- Flexible reserve Flexible reserve
- Interpretation Interpretation Annex 1 activities special reserve application historical aviation activity level
- Meaning of FA installation, etc. Meaning of FA installation, etc.
- Meaning of historical aviation activity level and Meaning of historical aviation activity level and attributable aviation activity ratio threshold figure
- Meaning of registry administrator Meaning of registry administrator
- ... and 4 more definitions
Exemptions 12
- s.8 Exempt non-commercial air transport operators
- Schedule 11 Transitional provisions: installations
- s.20 Cap for scheme years
- s.26 Installations: requirement for permit to carry out regulated activity
- s.33 Reporting aviation emissions
- s.37 Remittance of charges
- s.39 Inspections
- s.42 Admissible evidence
- s.48 Penalty notices: supplementary
- s.49 Regulator must publish names of persons subject to civil penalty under article 52
- Processing of applications and calculation of avia Processing of applications and calculation of aviation free allocation entitlement
- Restriction on disclosing information Restriction on disclosing information