Whilst I wholeheartedly agree that most of of seasoned boat owners are too stupid to worry... π€£... I believe that this could be a barrier for the newbie boater to invest in a VHF if they have even more hoops to jump through. Let's face it, doing the VHF course is a faff, even if it is in fact very useful. A newbie owner may see the Ofcom guidelines as the straw that breaks the camel's back, without having the contextual knowledge that we all do that the guidelines are just guidelines, and they are unenforceable in practical terms.
IMO Ofcom should be making it easier for boaters to stay safe, not harder.