It's not that obvious because it's not definitive. It's a set of regulations subject to additional and subsequent clarifications/exemptions which are not included within that document.
It's that fundamental failure of comprehension which largely accounts for the fact that Cummings is still in post and multiple media organisations are likely to find themselves on the wrong end of an IPSO ruling.
Throughout this debacle, the 'Get Cummings' brigade have shown a remarkable resemblance to those self-appointed 'legal loophole' champions whose combination of unshakeable certainty and woeful legal ignorance effortlessly turns a driving offence worth three points and a 60 quid fine into a driving ban and a two-year suspended sentence.
Hardly. Have you actually read the relevant regulations?