The National Union of Journalists has adopted Ireland's regulatory system as its preferred future model and Lord Leveson himself, according to a recent report, is struck by it.

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"We don't have any interest in reverse imperialism," claimed Professor John Horgan, the Irish Press Ombudsman, at an industry event in Belfast recently. It got a decent laugh. Smug he certainly isn't, but privately the former journalist/politician turned regulator must be rather enjoying Ireland's new status as perceived paragons (perhaps exporters) of press regulation.

The Irish system is fairly light-touch in its style. No compulsion to join, no fines if standards are breached. The emphasis is on membership by incentive. Carrots rather than sticks. In Ireland signing up to the Press council is supposed to give a newspaper greater safeguards in law if sued.

It remains untested by the courts, but to date all the main titles remain members. Notably, no one has done a "Desmond" (including Richard Desmond himself, who co-owns a newspaper in Ireland) and walked out (such as he did with the UK's Press Complaints Commission).

In Ireland the independence of the regulator is stressed. Horgan, as Ombudsman, is independent of press and government. He is accountable to a Press Council which has a majority of independent (ie non press) members (themselves appointed by an independent committee). Their most visible influence is seen on the printouts of newspaper cuttings which I'm shown in Horgan's Dublin office.

Their adjudications on certain complaints have to be printed in full in the relevant newspapers under the Council or Ombudsman's logos. If the offending article was a lead story, the rule is that the paper concerned has to print the ruling on pages 1-4 `with due prominence'.

Firm but fair is the approach, and to some extent in line with a great deal of calls for "greater independence" currently being made by the British press themselves. The latter's empathy with the Irish model extinguishes rapidly, however, over the mention of the word "statutory". In Ireland, the Press Council has a form of "statutory underpinning". The Council is mentioned in the Defamation Act 2009 which sets out minimum requirements which it must achieve in order to be recognised by Parliament.

The Council's chairman Dairthi O'Ceallaigh is adamant that this does not compromise the independence of the regulator: "Nobody" he states emphatically, "neither on the press side nor on the state side has in my experience sought to interfere with any decision we have made".

But the view among many in the the British press is that this "statutory underpinning" represents, in the words of former Guardian editor Peter Preston, 'the thin edge of the wedge'. In Ireland, Preston points out 'there is a 5 yearly review by Parliament of how [the Press Council]'s operating". That means, he argues, that politicians "can pile in and say something".

Others describe any form of statutory recognition as "crossing a political rubicon", anathema to the survival of a free press. The extent to which Lord Justice Leveson incorporates any `statutory' framework in his proposed regulatory model will surely become one of the most fierely debated political issues in the weeks to come.

For John Horgan, the British culture (arguably much more tolerant of privacy intrusions than the Irish) will need a "British solution". But when asked if he has any advice to Lord Justice Leveson, it is this: Use incentives before sanctions. It is an argument much easier to make, perhaps, in a country which hasn't spent the last year and a half immersed in a scandal which continues to see journalists hauled before the courts.

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