I think it is a fair assumption that ICO has pretty much given up on Pub Schemes. He could enforce s19 in theory as it is in Part 1 although its requirements and the model scheme are so vague that any enforcement notice would probably be ripped to shreds on challenge.
Beyond that there is not much you can do to push him. You cannot directly complain about non-compliance with s19 under s50 - only when it relates to a specific request and any incidental non-compliance with s19 will be pretty much left hanging if the request is actually answered.
This is reflected in the ludicrous state of most PSs. Go to the heart of FOI and consider the DCMS scheme. It clearly does not begin to comply with s19. It is not in the approved format - no mention e.g. of data sets - I suspect it has never been novated.
https://www.gov.uk/government/organisations/department-for-culture-media-sport/about/publication-scheme
The paucity of material available under the scheme and the difficulty in finding it is typical of .gov sites.
The first three class links are not what they say:
roles and responsibilities of department and staff at senior level - links to details of Ministers and MPs - nothing about staff
our sponsored bodies - doesn't identify which are sponsored by DCMS
DCMS organisation chart - dated 2013 which I doubt is current
I could not face going further.
If you wish to push proactive publication focus on Environmental Info. EIR R4(1) is much more forceful. If you analyse R18 particularly 18(4)(a)(ii) you can complain directly to ICO under s50 FOIA of a breach of R4. It does not need to hang off a request. And the Cheshire West case illustrates he will act if pushed. Many years ago I did a request asking a number of authorities what plans they had to implement R4. Several said "none". I regret not making a formal complaint of breach of R4 after receiving those responses.
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