The approach of the Information Commissioner's Office (ICO) to enforcement, often favouring softer tools in the toolbox such as reprimands, will have a net effect of forcing businesses to take divergent approaches to data protection law compliance in the UK and the EU. We anticipate that this regulatory and commercial divergence will continue, creating both opportunity but also complexity for businesses. The UK's data protection regulatory regime has historically had a reputation as a more pragmatic, business-friendly regime, especially compared with some EU jurisdictions, where the enforcement of data protection law has been more dogmatic.  The ICO has continued this more pragmatic approach as evident, for example, in its approach to consent or pay models and conducting transfer impact assessments following the Schrems II decision.