I basically stopped appeasing and trying to tick council boxes and got seriously legal with the councils; thank goodness this got Bromley Public Protection's attention and I finally got a zoom call. It was an excellent conversation and they promised to do their best to fix things after meeting the other council(s), fingers crossed! You cannot argue with the following:

The BFI Film Festival (October) do not apply any ratings at all, only occasional content notes. ‘Content warning: contains scenes of animal cruelty’ for example.

This means there is:

A direct precedent: The UK’s flagship festival (BFI) is running films in Lambeth, Southwark and Westminster without any ratings, BBFC certificates or council ratings.

Selective enforcement: Lambeth is effectively allowing the BFI “free rein” while blocking CPIFF. This is inconsistent, discriminatory and legally challengeable.

Undermining of the councils' “statutory compliance” claim: If it was truly unlawful for CPIFF to rate its own films, then BFI’s approach would also be unlawful — yet Lambeth and others permit it.

By definition councils are not compelled to require BBFC certification, council classification and should not be restricting CPIFF from using the same long-standing, proven system we have operated for 16 years.